In a civil rights case, in what circumstances will a plaintiff receive attorney's fees in excess of their actual damages?

Moreover, to whatever extent that civil rights fee-shifting cases might provide a useful comparison, they do not provide unequivocal support for ePRO's proportionality arguments. Because success in some meritorious civil rights cases will reasonably require attorney's fees in excess of the plaintiff's ultimate recovery, we have stated in that context that "[a] presumptively correct lodestar figure should not be reduced simply because a plaintiff recovered a low damage award." Cowan v. Prudential Ins. Co. of Am. , 935 F.2d 522, 526 (2d Cir. 1991). And we have recognized that the conduct of the opposing party

[880 F.3d 635]