it does provide that “none of the funds contained in this Act ... may be made available ... to pay the fees of an attorney who represents a party in or defends an IDEA proceeding which was initiated prior to the date of the enactment of this Act in an amount in excess of $4,000 for that proceeding.” Pub. L. No. 111-8,123 Stat. 524 (2009). The Act, therefore, lifted the fee cap for proceedings initiated after its March 11, 2009 enactment date, but barred the use of its funds to pay fees incurred in proceedings initiated before that date. See id.; see also Blackman, 633 F.3d at 1090. Because the plaintiffs fee claim is based on an administrative proceeding ini tiated in 2008, i.e. before the enactment of the 2009 Act, it is still subject to the fee cap. See Blackman, 633 F.3d at 1090 (<HOLDING>). d. Summary of Fees Allowed Requested Amount
holding that contingency fee contract did not cap award of attorneys fees where johnson had so held holding that the termination of the fee cap did not affect litigation in progress when the fee cap was in effect holding down the locking cap holding that the combination of the statutory cap and a high threshold for culpability for punitive damages in a title vii case confined a punitive damages award within the cap to a level tolerated by due process holding that the defendants could not be held in contempt for failure to pay more than the fee cap amount because the court cannot order the djefendants to violate an act of congress to pay the total award