Federal Circuit So Decides Despite Split In Authority.
In Parrott v. Shulkin, Case No. 2016-1450 (Fed. Cir. Mar. 13, 2017) (precedential), the Federal Circuit dealt with what Consumer Price Index (CPI)—national or local—should govern an upward adjustment of the $125 per hour fee award cap under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d)(2)(A). The Federal Circuit decided, despite a split in authority on the issue, that the local CPI should govern, pegged to the location where the attorney performed the work (meaning the attorney’s location, not the court venue).