In an appeal from an award of attorney fees under the Voting Rights Act of 1965, the Second Circuit took the opportunity to review its and other courts’ jurisprudence regarding the meaning and use of the term “lodestar” rates. The Second Circuit stated that its district courts should instead begin by assessing a “presumptively reasonable fee” which could then be subject to adjustment. The court also stated that in-district rates should generally apply unless the party seeking fees can satisfactorily demonstrate why the payment of higher out-of-district rates is appropriate in a particular case. The objective is to determine how much a reasonably prudent client would be willing to pay under all the circumstances.