In Alyeska Pipeline Co. v. Wilderness Society (1975) 421 U.S. 240, the United States Supreme Court held federal courts could not award attorney's fees in private attorney general actions without specific statutory authorization, on the rationale that Congress had preempted capacity to shift fees in actions based upon statutory law by explicitly directing payment of such fees only when it deemed such actions desirable. ( Id., at pp. 261-262.) The United States Supreme Court affirmed the continuing vitality of the "American Rule" that requires each party to bear the cost of its own attorneys' fees absent express statutory authority except in the following exceptional circumstances: (1) the common fund doctrine applies; (2) a party willfully disobeys a court order; or; (3) a party acts in bad faith.