What is the test for an award of attorney's fees under Section 2000e-5(k)?

42 U.S.C. 2000e-5(k) provides that "[i]n any action or proceeding under this subchapter the court, in its discretion, may allow the prevailing party ... a reasonable attorney's fee...." 42 U.S.C. 2000e-5(k). We review a trial court's decision to award attorney's fees to a prevailing party for an abuse of discretion. LaRouche v. Kezer, 20 F.3d 68, 71 (2d Cir.1994).

Determining whether an award of attorney's fees is appropriate requires a two-step inquiry. First, the party must be a "prevailing party" in order to recover. Farrar, 506 U.S. at 109, 113 S.Ct. at 571-72. If she is, then the requested fee must also be reasonable. Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 1939, 76 L.Ed.2d 40 (1983). The most important factor in determining the reasonableness of a fee is the degree of success obtained. Farrar, 506 U.S. at 114, 113 S.Ct. at 574-75.

Page 238