is normally one third to forty percent of the recovery, but the attorney does not recover a fee unless money is recovered for the client. States prohibit contingent fees in certain types of cases. For example, most states forbid contingent fees in criminal cases. States typically require that a fee agreement that involves a contingent fee be reduced to writing and signed by the client. Other fee arrangements With the ongoing recession of the 2000s, corporate clients began driving attorneys increasingly toward alternative fee arrangements (AFAs), which can include flat fees (per matter), fixed fees (for a "book" of matters), success bonuses, and other options. Recent studies suggest that when lawyers charge a fixed-fee rather than billing by the hour, they work less hard on behalf of clients and client get worse outcomes. Regulation of attorney fees In some types of cases, such as workers' compensation cases, attorney fees may be limited by statute, or subject to judicial review. Contingency fees in personal injury and medical malpractice cases are often capped by state law. In other cases, attorney fees may be subject to review for reasonableness. For example, in class action cases the court in which the case is resolved will review the attorney fees of class counsel for reasonableness. In a landmark 1985 decision, Walters v. National Association of Radiation Survivors, the U.S. Supreme Court held that statutory restrictions on attorney's fees are subject only to highly deferential rational basis review when challenged as limitations upon the First Amendment right to freedom of speech and the Fifth Amendment right to due process. In other words, if the legislature can articulate any rational basis for restricting attorney's fees, the court must defer to the legislature's considered judgment, and it would take an "extraordinarily strong showing" for a court to decide otherwise. The Court then held that Congress had a rational basis for restricting attorney's fees in veterans' benefits cases to $10. In 2006, the statute at issue in Walters was heavily revised so as to remove the $10 attorney's fee restriction for most veterans' benefits cases. However, the principles articulated by the Walters court remain the law of the land for attorney's fees in general. Long before the Walters case, conservatives in the United States had begun to put forward tort reform proposals to restrict attorney fees, which gained traction in the 1970s. Medical malpractice tort reforms often include maximum