Awards of Attorneys' Fees by Federal Courts and Federal ...
Jun 20, 2008 · Horn, 29 F.3d 754, 759 (1 st Cir. 1994) (sovereign immunity precludes use of supervisory power to order the United States to pay the fees and costs incurred by criminal defendants in litigating prosecutorial misconduct issue; but see, P.L. 105-119 (1997), discussed below in Ch. XVII). Although the Supreme Court noted in Chambers,
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