The U.S. Supreme Court case New York Gaslight Club, Inc., et al. v. Carey in 1979 revolved around the issue of whether attorney's fees could be awarded to a prevailing party under Title VII of the Civil Rights Act of 1964 for legal services rendered at both state and federal levels. The plaintiff, Lorelei J. Carey, filed complaints with the State Division of Human Rights alleging that she had been discriminated against by her employer based on sex in violation of New York law and Title VII. After winning her case at the state level but not being granted attorney’s fees as part of her award, she sought relief in Federal District Court which ruled in favor of granting those fees for work done before it but not for work done before the State Division. On appeal to Supreme Court, it held that Congress intended to allow successful plaintiffs who are forced to litigate their claims under Title VII at both state and federal levels should be able to recover their attorney's fees associated with pursuing these claims at both levels if they prevail.

In the dissenting opinion for New York Gaslight Club, Inc. v. Carey, Justice Rehnquist disagreed with the majority's interpretation of Title VII of the Civil Rights Act and its provision allowing attorney’s fees to be awarded in state proceedings. He argued that Congress did not intend for this federal law to apply so broadly as to cover costs incurred during state-level litigation or administrative procedures prior to any federal court involvement. The legislative history of Title VII, according to him, suggested that it was meant only for cases brought before federal courts under its jurisdictional grant and not those pursued initially at a state level. Therefore, he believed that awarding such fees went beyond what Congress had intended when drafting this legislation.