limits on plaintiffs' attorney fees, such as the percentage schedule in California's Medical Injury Compensation Reform Act of 1975. In 2004, Florida passed a constitutional amendment limiting contingent fees in medical malpractice cases. Although some people have objected to these laws as an unfair restriction on freedom of contract, Justice William Rehnquist shot down that argument in his majority opinion for the Walters court. Rehnquist implied that there was no principled way for the Court to overturn such laws as a violation of freedom of contract without returning to the now-discredited paternalism of the Lochner era, in which the Court had routinely invoked freedom of contract as an excuse to overturn laws regulating minimum wages and child labor. Justice John Paul Stevens filed a dissenting opinion in which he specifically attacked the majority opinion on that point, among others; he began and ended his dissent with the accusation that the majority "does not appreciate the value of individual liberty". Who pays Most countries operate under a "loser pays" system, sometimes called the English rule (in English law it is described as "costs following the event"). Under the English rule, the losing party pays the successful party's legal costs (including lawyers' fees), as well as other court costs. United States The United States is a notable exception, operating under the American rule, whereby each party is generally liable only for costs (e.g., filing fees, motion fees, fees for service of process, etc.) but not the other side's attorney's fees unless a specific statute or rule of court provides otherwise. Some tort reform advocates propose adopting a "loser pays" rule in the United States. Federal district court and Court of Appeals judges award costs to the prevailing party under Federal Rules of Civil Procedure 54. In some jurisdictions, statutes may permit judges and juries to independently impose "loser pays"; for example, a judge may say: "I am ruling for the plaintiff on the amount of $[sum] plus all court costs and attorney fees". But generally, state court judges have no common law authority to award such fees against the losing party. Some settlement agreements, arbitration agreements and other extrajudicial contracts may also stipulate a loser-pays arrangement. A number of federal laws provide for an award of attorney fees for a prevailing plaintiff, such as: Antitrust actions Civil rights violations, see Civil Rights Attorney's Fees Award Act of 1976 Class actions Copyright and