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A previous edition of Weil's Class Action Monitor discussed the Eleventh Circuit's decision in Johnson v. NPAS Sols., LLC, 975 F.3d 1244 (11th Cir. 2020), which held class action settlement incentive awards for class representatives run afoul of a pair of nineteenth century U.S. Supreme Court decisions: Trustees v. Greenough, 105 U.S. 527 (1882) and Cent. R.R. & Banking Co. v. Pettus, 113 U.S. 116 (1885).
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