(concurring in the result). This case presents the question whether a prevailing party is entitled to a second award of attorney fees after the party has already been compensated for his reasonable attorney fees. I fully concur with the majority’s conclusion that, here, plaintiff may not recover attorney fees under the mediation rule, MCR 2.403(0), because he was already compensated for his reasonable attorney fees pursuant to MCL 37.1606(3); MSA 3.550(606) (3) of the Handicappers’ Civil Rights Act. However, the majority, in dicta,1 leaves open the pos*527sibility that duplicative recovery of attorney fees may be available when the applicable statutes or court rules further different purposes. The majority states that it agrees with Court of Appeals cases “that hold that where the purposes of the court rules and statutes providing for an award of attorney fees serve independent policies, recovery under both may be appropriate.” Ante at 522. On this point, I disagree.
The common purpose of both statutes and court rules authorizing an award of attorney fees is simply to suspend the operation of the “American rule” and require the losing party to reimburse the prevailing party for his reasonable attorney fees. Accordingly, once a party has been so compensated, no further award is warranted.
As the majority states, Michigan follows the “American rule” with regard to payment of attorney fees, under which attorney fees are not generally recoverable from the losing party as costs in the absence of an exception set forth in a statute or court rule expressly authorizing such an award. Popma v Auto Club Ins Ass’n, 446 Mich 460, 474; 521 NW2d 831 (1994); see also MCL 600.2405(6); MSA 27A.2405(6).2 Consistent with the narrow construction that must be given these exceptions,3 I believe that the common objective of statutes and court rules authorizing attor*528ney fee awards is only to suspend the operation of the American rule and require the losing party to compensate the prevailing party for reasonable attorney fees under circumstances that warrant such compensation. The common objective cannot, consistent with a narrow interpretation, be to award something more than actual costs, i.e., duplicative costs.
The majority builds its argument on the fact that the various court rules and statutes that articulate exceptions to the American rule rest on different rationales, e.g., to deter discrimination4 or to discourage needless litigation.5 These rationales, however, only convey why the enacting body chose to allow recovery of attorney fees in a particular situation when almost universally that is not done. In no sense do these explanations of the circumstances under which there will be deviation from the usual rule— the American rule — alter the fact that the overarching objective of such exceptions is only to compensate the prevailing party for reasonable attorney fees. The reason there can be no expansive reading to provide more than a simple waiver of the American rule is that no statute or court rule expressly states that it is designed to provide for the duplicative recovery of attorney fees.
Indeed, under the logic of the majority opinion, if a prevailing party can convince a court that there are separate purposes under distinct provisions for attorney fees, multiple attorney fees can be recovered. We *529should anticipate that the potential for such a windfall will invite exploration of the limits of the majority’s dicta and, accordingly, produce much future litigation in which the lower courts, and eventually this Court, will be asked to adjudicate claims that have at their root a flawed understanding of the import of the American rule and its exceptions.
For these reasons, I would hold that the common purpose of exceptions to the American rule is to relieve prevailing parties of all or part of the expenses of litigation. Because punitive sanctions are not generally permitted in Michigan, these exceptions permitting an award of attorney fees are necessarily in the nature of compensatory damages. Thus, a prevailing party’s recovery is limited to reimbursement of a reasonable attorney fee as determined by the trial court, regardless of the number of exceptions that apply. Accordingly, I disagree with the majority’s adoption of the principle that the independent purposes underlying statutes or court rules that provide for recovery of attorney fees may justify duplicative recovery of attorney fees.
As the majority notes, attorney fees may also be awarded where provided by contract of the parties, Zeeland Farm Services, Inc v JBL Enterprises, Inc, 219 Mich App 190, 195; 555 NW2d 733 (1996), or under a limited number of common law exceptions to the American rule recognized in Michigan. See In re Thomas Estate, 211 Mich App 594, 602; 536 NW2d 579 (1995); Popma, supra at 475. But these situations are not at issue here.
In re Petition of Consumers Power Co, 335 Mich 360, 366; 56 NW2d 217 (1953); Auto Club Ins Ass’n v State Farm, Ins Cos, 221 Mich App 154, 167; 561 NW2d 445 (1997).
See, e.g., King v General Motors Corp, 136 Mich App 301, 307-308; 356 NW2d 626 (1984); Jenkins v Southeastern Michigan Chapter, American Red Cross, 141 Mich App 785, 801; 369 NW2d 223 (1985).
See, e.g., Dep’t of Transportation v Dyl, 177 Mich App 33, 36; 441 NW2d 18 (1989).