b'the 1800s, the Court held that a plaintiff suing on behalf of a class cannot be paid a salary or be reimbursed for his personal expenses. This decision is significant as incentive awards for class plaintiffs are very common in class action litigation. Acknowledging this, the Eleventh Circuit invited either Congress or the Supreme Court, in the event that it disagrees with the Eleventh Circuits decision, to either provide for incentive awards by statute or overrule the Supreme Court precedent prohibiting named plaintiffs from being paid salaries or being reimbursed for his personal expenses. Looking Ahead to 2021In 2020, we expected the Supreme Court to resolve the issue of the Dodd-Frank Acts for-cause removal provision in Seila Law LLC v. CFPB, which it did, with the Ninth Circuit on remand finding that any constitutional injury to Seila Law through the CFPBs structure was remedied and the CID properly ratified by the CFPBs Director. Now that the Supreme Court granted certiorari in Collins v. Mnuchin, No. 19-0422where the constitutionality of the FHFA structure is at issueit will remain to be seen if the Court will extend the same reasoning to Collins or any other challenges to other agencies structures that may arise in 2021. Please refer to the What Were Watching: 2021 Emerging Issues section for an overview of Supreme Court cases set for hearing on the Courts 2021 docket. What to WatchSupreme Courts resolution of TCPA definition ofATDS.Continued constitutional challenges to government agencies and federal regulations. Potential Circuit Court split between the Ninth and Second Circuits regarding HOLAs preemption of state laws.54'