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We first recognized the substantial benefit theory in Silva v. Botsch, 121 N.H. 1041 (1981).

Mills v. Electric Auto-Lite, 396 U.S. 375, 396-97 (1970) (“To award attorneys’ fees [to a 7 The trial court in part relied upon our decision in Silva v. Botsch, 121 N.H. 1041 (1981), in which we held that a selectman was entitled to attorney’s fees after he had successfully sued his fellow selectmen, as authority for awarding fees against a private party.

Under the “substantial benefit” theory set forth in Silva v. Botsch, 121 N.H. 1041, 1043 (1981), attorney’s fees may be awarded when a litigant’s action confers a “substantial benefit” upon the general public.

“When overriding considerations so indicate, the award of fees lies within the power of the court, and is an appropriate tool in the court’s arsenal to do justice and vindicate rights.” Silva v. Botsch, 121 N.H. 1041, 1043-44 (1981) (brackets omitted).

Instead, relying on Town of Littleton v. Taylor, 138 N.H. 419 (1994), Foster v. Hudson, 122 N.H. 150 (1982), Silva v. Botsch, 121 N.H. 1041 (1981), and principally, King v. Thomson, 119 N.H. 219 (1979), the petitioners argue that they have a common law right, enforceable by the court, to reimbursement of attorney’s fees under the “public trust” doctrine.

Moreover, the public trust cases cited by the Tabers to support their argument that they should be awarded attorney’s fees for benefiting the citizens and taxpayers of the State are inapposite.

Nor do the cases cited by the plaintiff, Silva v. Botsch, 121 N.H. 1041, 437 A.2d 313 (1981), and Foster v. Town of Hudson, 122 N.H. 150, 441 A.2d 1183 (1982), sustain the award of attorney’s fees.

Irwin Marine, Inc. v. Blizzard, Inc., 126 N.H. 271, 276, 490 A.2d 786, 790-91 (1985); Silva v. Botsch, 121 N.H. 1041,1043, 437 A.2d 313, 314 (1981).

The defendant argues that she should be awarded attorney’s fees under the “public trust” theory set forth in Silva v. Botsch, 121 N.H. 1041, 1043, 437 A.2d 313, 314 (1981).

Assuming that RSA 677:15, V does *347 not affect the court’s power to award attorney’s fees, cf. Silva v. Botsch, 121 N.H. 1041, 1044, 437 A.2d 313, 315 (1981) (finding that “costs” as defined in RSA chapters 490 and 525 do not include attorney’s fees), we find nevertheless that an award of fees is inappropriate.

The general rule in this State is that each party to a lawsuit is responsible for payment of his or her own lawyer’s bill.

Silva v. Botsch, 121 N.H. 1041, 1043, 437 A.2d 313, 314 (1981); Pugliese v. Town of Northwood, 119 N.H. 743, 752, 408 A.2d 113, 118 (1979); Morse v. Ford, 118 N.H. 280, 281, 385 A.2d 229, 230 (1978); Harkeem v. Adams, 117 N.H. 687, 690, 377 A.2d 617, 619 (1977).

Although under the general American rule each party pays for his own attorney’s fees, the legislature and judiciary have created a number of flexibly applied exceptions.

New Hampshire still adheres to the rule that attorney’s fees are not awarded except in limited circumstances.

Royer v. Adams, 121 N.H. 1024, 1028, 437 A.2d 316, 319 (1981); Silva v. Botsch, 121 N.H. 1041, 1044, 437 A.2d 313, 315 (1981).

Douglas, J. This appeal raises the question of whether a police chief is a public official holding a position of sufficient trust so as to come within the ambit of Silva v. Botsch, 121 N.H. 1041, 437 A.2d 313 (1981), in which we held that certain elected public officials are entitled to reimbursement for attorney’s fees under a “public trust” theory.

Silva v. Botsch, 121 N.H. 1041, 1044, 437 A.2d 313, 315 (1981) (allowable costs under RSA 525:13-19 do not include attorney’s fees).