See Kerns, 176 F.3d at 804 (providing the standard of review). Eastern has not shown such an abuse of discretion. Notwithstanding this fact, we emphasize that prior fee awards are not controlling authority establishing a prevailing market rate for later cases. Were that the case, the hourly rates of attorneys could be predetermined by erroneous prior awards, or lose the capacity to respond to changing market conditions. See Farbotko v. Clinton Cnty. of N.Y., 433 F.3d 204, 209 (2d Cir.2005) (observing that “Recycling rates awarded in prior cases without considering whether they continue to prevail may create disparity between” compensation available under a fee-shifting scheme and that which is available in the market); Dillard v. City of Greensboro, 213 F.3d 1347, 1355 (11th Cir.2000) (<HOLDING>). At the heart of the requirement that hourly
holding that direct evidence by definition is evidence that does not require an inferential leap between fact and conclusion holding the aggregate value of the land and its improvements is the controlling value recognizing the inferential evidentiary value of prior awards but cautioning against giving them controlling weight over superior evidence holding determination of property value in case to decide if assessed value was excessive is not a liquidated demand where only evidence of property value was the conclusory allegation of value in plaintiffs unsworn petition holding that the trial courts damages award was against the manifest weight of the evidence because it was based upon inadmissible evidence