What is the equitable substantial benefit doctrine on the basis of attorney fees?

The equitable substantial benefit doctrine "'permit[s] reimbursement [of attorneys fees] in cases where the litigation has conferred a substantial benefit on the members of an ascertainable class, and where the court's jurisdiction over the subject matter of the suit makes possible an award that will operate to spread the costs proportionately among'" the members of that class. (Serrano v. Priest (1977) 20 Cal.3d 25, 40, fn. 10. (Serrano).) The cost is spread, for example, when a shareholder prevails in a derivative action and recovers attorney fees. The award of attorney fees, in effect, makes "it possible to assess fees

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