In what circumstances have attorney's fees been assessed as assessments of interest under the Civil Rights Act?

In such cases, where awards of attorney's fees are generally understood to complement the purposes of the relevant prohibitory statutes by encouraging private enforcement of the statutes themselves, assessments of interest on fee awards have been seen as necessary incidents to enforcement. See, e.g., Spain, 690 F.2d at 748; see also Gates v. Collier, 616 F.2d 1268, 1275 (5th Cir.1980) ("[T]he awarding of interest [on attorney's fees] is entirely consistent with the purpose of the Act; to ensure effective enforcement of the civil rights laws").