In Muniz v. UPS (9th Cir., Dec 2013), a case under a statute awarding attorneys fees and costs to the prevailing party, the Ninth Circuit Court of Appeals upheld a trial court award of attorneys fees and costs which was 26x the damages awarded by the jury. Decisions like this one should help to deter the time-wasting shotgun litigation tactics of insurers under such statutes (such as HRS section HRS 431:10-242).