of her entitlement to “to offer evidence in support of the reasonableness of her request.” Id. at 267. And second, because statutory fee litigation is adversarial litigation, there is no need to allow the district court to reduce a fee award on its own initiative. Id. Bell contends that the principle announced in Cunningham I that a judge may not sua sponte reduce a request for attorneys’ fees should extend beyond civil rights cases and apply equally to ERISA cases. We agree. The reasoning articulated in Cunningham I with respect to this principle is not unique to the area of civil rights, and we can see no reason to create a different jurisprudence of fee awards in ERISA cases. Cf. Delaware Valley Citizens’ Council for Clean Air v. Pennsylvania, 762 F.2d 272, 275 (3d Cir.1985) (<HOLDING>), modified on other grounds, 478 U.S. 546, 106
holding that a case awarding fees under 42 usc  1988 has no application in a private claim for attorneys fees sounding in mississippi contract law recognizing absolute immunity to suits under 42 usc  1988 holding defendant may receive only the portion of his fees under 42 usc  1988 that he would not have paid but for the frivolous claim holding that 42 usc  1988 authorizes the grant of attorneys fees for services on appeal though statute does not specifically so provide holding that the same standards apply for setting reasonable attorneys fees under the clean air acts fee shifting provision as under 42 usc  1988