competent counsel); see also Gaff-ney v. City of Allentown, 1998 WL 32758 (E.D.Pa.) (discussing restricted circumstances under which enhancement is allowable). Plaintiff is not arguing that any of these three situations are applicable. Instead, plaintiff argues for an enhancement multiplier based on the novelty of the issue. However, the Supreme Court has held that the arguments advanced by plaintiff are not grounds for an upward adjustment. The Court in Blum indicated that novelty of an issue is not grounds for an upward adjustment because compensation for the novelty is reflected in both the hourly rates charged and the number of hours expended by counsel. See Blum v. Stenson, 465 U.S. 886, 899, 104 S.Ct. 1541, 1549, 79 L.Ed.2d 891 (1984); see also Gaffney, 1998 WL 32758 at *4 (<HOLDING>). 2. Downward Adjustment “The court can adjust
recognizing that novelty of issue is reflected in lodestar quoting pennsylvania v delaware valley citizens council for clean air 478 us 546 565 106 sct 3088 92 led2d 439 1986 holding that an increase in the mandatory minimum sentence based on judicial factfinding does not evade the requirements of the fifth and sixth amendments and reaffirming mcmillan v pennsylvania 477 us 79 106 sct 2411 91 led2d 67 1986 holding that a postconviction petitioner has 60 days from the date of publication of 1997 philadelphia magazine article to raise claims based thereon under batson v kentucky 476 us 79 106 sct 1712 90 led2d 69 1986 holding that batson v kentucky 476 us 79 106 sct 1712 90 led2d 69 1986 does not apply retroactively to cases on collateral review holding that a statute did not  directly and substantially interfere with family living arrangements despite district courts finding that the wife and children of one striking worker left his household after he was denied food stamps and that the couple subsequently divorced quoting lyng v castillo 477 us 635 637 106 sct 2727 2729 91 led2d 527 1986 quoting zablocki 434 us at 38687  n 12 98 sct at 681  n 12