Justice WALLACE
delivered the opinion of the Court.
This case involves claims of hostile work environment and sexual harassment under New Jersey’s Law Against Discrimination (LAD), N.J.S.A. 10:5-1 to -49. Plaintiff filed a complaint against Bob Ciasulli (Ciasulli) and various of his wholly-owned corporations and their employees. Prior to trial, all defendants were dismissed except for Ciasulli, Bob Ciasulli Auto Group (Auto Group), and Bob Ciasulli’s Mack Auto Mall, Inc. (Mack Auto Mall). At trial, the court dismissed plaintiffs claim for emotional distress damages and the claim against Ciasulli individually. The jury found Mack Auto Mall liable for sexual harassment in the work[74]*74place, but did not find that plaintiff suffered any damages. Despite her failure to prove damages, the court awarded attorney fees to plaintiff as a prevailing party. The Appellate Division reversed in part, and affirmed in part. Tarr v. Bob Ciasulli’s Mack Auto Mall, Inc., 360 N.J.Super. 265, 822 A.2d 647 (2003).
We granted certification, 178 N.J. 29, 834 A.2d 403 (2003), and granted amicus curiae status to the National Employment Lawyers Association of New Jersey (amicus). We now affirm in part, and reverse in part. We hold that plaintiff presented sufficient evidence of emotional distress damages to submit that issue to the jury, that the trial court properly dismissed the complaint against Ciasulli, and that to be considered a prevailing party under the LAD for purposes of entitlement to counsel fees, a party must receive some affirmative relief in the form of damages, injunctive relief, or declaratory relief.
I.
Plaintiff began working for Mack Auto Mall in late July 1994 as a finance and insurance manager. Plaintiffs immediate supervisor, Kelly Bragg, reported to Patrick Grimaldi, the general manager of Mack Auto Mall. Plaintiff and Bragg shared office space located near the sales floor. Plaintiff worked at Mack Auto Mall until July 1995, when she left, allegedly because of sexual harassment in the workplace. Nevertheless, plaintiff returned to the job in August 1995 and remained until April 1996 when she again resigned because of the asserted sexual harassment.
At trial, plaintiff described the extensive and pervasive sexual harassment that she endured from a group of particularly offensive male employees. At various times, those employees would refer to women in demeaning gutter slang that we need not repeat here. Plaintiff testified that one employee would leave pornographic material on his desk, draw sexually explicit pictures on deal envelopes, open his legs and describe his sexual organ in detail, and discuss his sexual escapades with various women, some of whom were very young. Another employee regularly com[75]*75mented to her about his wishes to have a sexual encounter with her, and propositioned her to have sex in a “broom closet.” Plaintiff also had to deal with another employee who regularly made offensive sexual comments to her in the presence of strangers, intimating that his presence would sexually stimulate her.
Plaintiff stated that Grimaldi heard much of the abusive conduct, but made no effort to stop it. On one occasion he made a sexual comment when plaintiff dropped something in front of him. Also, Grimaldi once told plaintiff that she should loosen her blouse to help sell a warranty to a customer.
Plaintiff testified that the constant abuse made her feel extremely uncomfortable and led her to quit in July 1995. However, she returned a short time later because she needed the job and because Bragg, who was also subjected to sexual harassment, assured her that the situation would improve. Plaintiff’s testimony of sexual harassment was corroborated by various witnesses, including Bragg and two other coworkers.
Plaintiff stated that she was constantly embarrassed by the disgusting comments and conduct of the male employees. She explained that she often wanted to crawl under her desk. Her frustration with the abusive work environment reached a point where she regularly cried on her way home from work. Plaintiff eventually quit in April 1996.
Plaintiff presented limited evidence of Ciasulli’s direct involvement with the management of Mack Auto Mall. She testified that Ciasulli held monthly meetings attended by all sales personnel. Bragg testified that she considered Ciasulli her supervisor, and that she called him directly when her immediate supervisor could not resolve a problem. A former manager at Mack Auto Mall also testified that Ciasulli once told him to fire a salesperson following allegations of sexual harassment because the victim had threatened to file a complaint with the Attorney General’s office.
At the close of plaintiff’s case, the trial court dismissed plaintiffs emotional distress claim. The court ruled that the elements [76]*76of emotional distress are the same in both discrimination cases and in tort cases, and that the evidence that plaintiff was temporarily upset was insufficient to establish her claim.
Ciasulli also testified. He stated that he was the sole owner of the Auto Group dealerships and that there was a direct employee hotline through which employees could call his office. He added that if a corporate officer could not resolve a problem, an employee could come to him for a final resolution. He remarked that other female employees had filed sexual harassment claims, noting that their embellished complaints were suitable for a Hollywood script.
At the close of all the evidence, the trial court dismissed the complaint against Ciasulli, individually, and Auto Group. The case was submitted to the jury solely against plaintiffs employer, Mack Auto Mall. In answer to special interrogatories, the jury found that plaintiff was the victim of sexual harassment in the workplace, but that she suffered no economic loss. The court concluded that plaintiff was entitled to attorney fees as a prevailing party because the jury found in plaintiffs favor on the sexual harassment and hostile workplace claims.
Plaintiff appealed the dismissals of her emotional distress damages claim and of her complaint against Auto Group. All three defendants cross-appealed from the order awarding counsel fees. The Appellate Division reversed the order dismissing the emotional distress damages and the complaint against Ciasulli individually. Tarr, supra, 360 N.J.Super. at 280-81, 822 A.2d 647. The Appellate panel remanded for a determination of Ciasulli’s individual liability, ordered a new trial on damages, both compensatory and punitive, and affirmed the orders dismissing the complaint against Auto Group and awarding counsel fees to plaintiff. Ibid.
II.
The resolution of the emotional distress damages claim requires us to consider whether the LAD permits a lower evidentiary threshold for recovery of such damages than is necessary to [77]*77sustain a cause of action for intentional infliction of emotional distress.
A.
We begin by reviewing the elements of a common law cause of action for intentional infliction of emotional distress. To prevail on such a claim “[t]he plaintiff must establish intentional and outrageous conduct by the defendant, proximate cause, and distress that is severe.” Buckley v. Trenton Saving Fund Soc’y, 111 N.J. 355, 366, 544 A.2d 857 (1988). Generally, for the conduct to be actionable, “the emotional distress ... must be ‘so severe that no reasonable [person] could be expected to endure it.’ ” Id. at 366-67, 544 A.2d 857 (quoting Restatement (Second) of Torts § 46 comment j at 77 (1965)). Because the severity of the emotional distress raises questions both of law and fact, the court “decides whether as a matter of law such emotional distress can be found, and the jury decides whether it has in fact been proved.” Id. at 367, 544 A.2d 857.
Beyond a cause of action for emotional distress, our courts have long recognized emotional distress damages as a component of various intentional torts and breach of contract claims. See, e.g., Zahorian v. Russell Fitt Real Estate Agency, 62 N.J. 399, 416, 301 A.2d 754 (1973) (awarding compensatory damages for pain and suffering inflicted upon plaintiff in denial of apartment rental because of her sex and marital status); Morris v. MacNab, 25 N.J. 271, 280, 135 A.2d 657 (1957) (permitting recovery for wife’s “shame, humiliation and mental anguish” caused by the defendant’s fraudulent inducement into bigamous marriage); Harris v. Delaware, Lackawanna & W. R.R., 82 N.J.L. 456, 458, 82 A. 881 (E. & A.1912) (holding conductor hable in trespass for “humiliation and indignity” caused by wrongful conversion of railroad ticket); Kuzma v. Millinery Workers Union Local No. 24, 27 N.J.Super. 579, 592, 99 A.2d 833 (App.Div.1953) (permitting recovery for mental anguish and emotional distress supported by tort of malicious interference with employment); Spiegel v. Evergreen Ceme[78]*78tery Co., 117 N.J.L. 90, 96-97, 186 A 585 (Sup.Ct.1936) (approving damages for mental anguish caused by cemetery’s breach of contract resulting in unnecessary exhumations); Gray v. Serruto Builders, Inc., 110 N.J.Super. 297, 315-18, 265 A.2d 404 (Ch.Div. 1970) (ruling that Director of Civil Rights Division has authority to award damages for emotional distress caused by racial discrimination in renting).
B.
The Legislature amended the LAD to authorize recovery of emotional distress damages for discrimination claims. L. 1990, c. 12, § 1. The LAD now mandates courts to construe its provisions broadly:
The Legislature further finds that because of discrimination, people suffer personal hardships, and the State suffers a grievous harm. The personal hardships include: economic loss; time loss; physical and emotional stress; and in some cases severe emotional trauma, illness, homelessness or other irreparable harm resulting from the strain of employment controversies; relocation, search and moving difficulties; anxiety caused by lack of information, uncertainty, and resultant planning difficulty; career, education, family and social disruption; and adjustment problems, which particularly impact on those protected by this [A]ct. Such harms have, under the common law, given rise to legal remedies, including compensatory and punitive damages. The Legislature intends that such damages be available to all persons protected by this [A]ct and that this [A]ct shall be liberally construed in combination with other protections available under the laws of this State.
[N.J.S.A. 10:5-3 (emphasis added).]
A post-amendment case permitted emotional distress damages under the LAD in the absence of expert testimony. Rendine v. Pantzer, 276 N.J.Super. 398, 648 A.2d 223 (App.Div.1994), aff'd as modified, 141 N.J. 292, 661 A.2d 1202 (1995). In that case, the female plaintiffs instituted an action under the LAD seeking damages for wrongful termination based on pregnancy. Id. at 421, 648 A.2d 223. The plaintiffs were awarded emotional distress damages. Id. at 439, 648 A.2d 223. On appeal, the defendant claimed the award for emotional distress should have been dismissed, or alternatively, the award was excessive because the plaintiffs did not submit any expert testimony or objective corroboration of their claims. Id. at 438, 442, 648 A.2d 223. The [79]*79Appellate Division affirmed the award, noting that “[t]he Legislature [in N.J.S.A. 10:5-3] has specifically authorized recovery for the type of emotional distress [the] plaintiffs claimed.” Id. at 439, 648 A.2d 223. The court reasoned that:
Although defendant’s discriminatory treatment did not cause plaintiffs to relocate or suffer illness or homelessness, both plaintiffs described in detail their inconvenience and economic loss, physical and emotional stress, anxiety in searching for reemployment, uncertainty, career and family disruption and other adjustment problems. Plaintiffs’ problems seem precisely the type for which the Legislature intended compensation.
[Id. at 440, 648 A.2d 223.]
This Court affirmed the damage award, similarly relying on the 1990 amendment to the LAD authorizing emotional distress damages, and rejected the defendant’s contention that expert testimony or independent corroborative evidence was necessary to support the award of emotional distress damages. Rendine, supra, 141 N.J. at 312, 661 A.2d 1202.
C.
Federal authorities have reached the same conclusion under federal statutes. The Fifth Circuit Court of Appeals upheld an emotional distress award to a Title VII pregnancy discrimination plaintiff that was based solely on the plaintiffs testimony that her employer’s discrimination caused her low self-esteem, serious hardship in procuring daycare for her newborn child, anxiety attacks, stress, and sleeplessness. Migis v. Pearle Vision, Inc., 135 F.3d 1041, 1045-46 (5th Cir.1998). In affirming the award, the Fifth Circuit concluded that the plaintiffs testimony was sufficiently detailed to support the award. Id. at 1047. The court also observed that corroborating testimony and medical evidence are not required in every case involving nonpecuniary compensatory damages. Ibid.; see also Smith v. Northwest Fin. Acceptance, Inc., 129 F.3d 1408, 1413 (10th Cir.1997) (finding Title VII plaintiffs testimony that supervisor’s offensive comments were intolerable and caused humiliation and loss of self-respect was sufficient to establish hostile work environment); Kim v. Nash Finch Co., 123 F.3d 1046, 1065 (8th Cir.1997) (affirming emotional distress [80]*80damages in Title VII claim supported solely by employee’s and spouse’s testimony about sleeplessness, stress anxiety, humiliation, and depression); Turic v. Holland Hospitality, Inc., 85 F.3d 1211, 1215 (6th Cir.1996) (“A plaintiffs own testimony, along with the circumstances of a particular case, can suffice to sustain the plaintiffs burden [to prove emotional distress].”); Bolden v. Southeastern Pa. Transp. Auth., 21 F.3d 29, 34 (3d Cir.1994) (holding expert testimony not necessary to corroborate emotional distress damages in federal civil rights action); DeNieva v. Reyes, 966 F.2d 480, 487 (9th Cir.1992) (affirming damages award premised solely on plaintiffs testimony about emotional and physical distress including insomnia, dizziness, and vomiting); Secretary, U.S. Dep’t of Hous. & Urban Dev. ex rel. Herron v. Blackwell, 908 F.2d 864, 872-73 (11th Cir.1990) (upholding emotional distress damages for housing discrimination based on plaintiffs testimony regarding humiliation, insomnia, and headaches).
D.
The preceding cases illustrate that claims for emotional distress of varying degrees have been recognized where a wrong is willful. A cause of action asserting discrimination is willful rather than negligent. Gray, supra, 110 N.J.Super. at 315, 265 A.2d 404.
We have declared that the purpose of the LAD is “the eradication ‘of the cancer of discrimination.’ ” Fuchilla v. Layman, 109 N.J. 319, 334, 537 A.2d 652 (quoting Jackson v. Concord Co., 54 N.J. 113, 114, 253 A.2d 793 (1969)), cert. denied, 488 U.S. 826, 109 S.Ct. 75, 102 L.Ed.2d 51 (1988). The LAD expressly reflects the public policy considerations of protection of “the civil rights of individual aggrieved employees [and protection of] the public’s strong interest in a discrimination-free workplace.” Lehmann v. Toys ‘R’ Us, Inc., 132 N.J. 587, 600, 626 A.2d 445 (1993). Underlying the LAD’s expansive language advocating the elimination of discrimination is also the directive that we compensate victims for economic and noneconomic injuries attributable to an employer’s discriminatory conduct. N.J.S.A 10:5-3.
[81]*81We are convinced that the Legislature intended victims of discrimination to obtain redress for mental anguish, embarrassment, and the like, without limitation to severe emotional or physical ailments. We adopt as our own, the reasoning of Judge Pressler in writing for the Appellate Division.
To suffer humiliation, embarrassment and indignity is by definition to suffer emotional distress. Emotional distress actually suffered in that manner by the victim of proscribed discrimination is compensable without corroborative proof, permanency of response, or other physical or psychological symptoms rendering the emotional distress severe or substantial. The quantum of compensation, which may be nominal in the terms we have described, is dependent upon the relevant factors we have identified including duration of the discriminatory conduct, its public nature, and its content and may be enhanced by such additional proofs of indicia of suffering as plaintiff may adduce. We add only that the duration and the content of the conduct asserted here clearly, in our view, warrants an award in some amount. No reasonable woman can be expected to have endured the constant and prolonged barrage of the extraordinarily demeaning and degrading sexual harassment to which this plaintiff was subjected without humiliation, embarrassment and loss of personal dignity and that was the emotional distress to which she testified. We leave the question of quantum to the fact finder.
[Tarr, supra, 360 N.J.Super, at 276-77, 822 A.2d 647.]
Our dissenting colleagues invoke Taylor v. Metzger, 152 N.J. 490, 706 A.2d 685 (1998), to reach a contrary conclusion concerning the standard of proof for emotional distress damages under the LAD. There, the Court found sufficient evidence of workplace discrimination for plaintiff to proceed on her claim of LAD racial discrimination. Further, the Court clarified the test for an intentional infliction of emotional distress cause of action as set forth in Buckley, id. at 508-09, 706 A.2d 685, and found that the plaintiffs evidence was sufficient to support that cause of action as well, id. at 521, 706 A.2d 685. There was no need for the Court to address the issue we face today because the “evidence ... relevant to [the] plaintiffs claim of emotional injury would overlap, if not duplicate, that proffered to establish her LAD claim.” Id. at 509, 706 A.2d 685. Here, plaintiffs claim is limited to her proofs under the LAD, and if she prevails, she may recover attorney fees that are not available for a cause of action for intentional infliction of emotional distress.
[82]*82This Court noted long ago that “[g]iven the breadth of individual and societal harms that flow from discrimination and harassment, to limit the LAD’s application to only those eases in which the victim suffered, or could have suffered, serious psychological harm would be contrary to its remedial purpose.” Lehmann, supra, 132 N.J. at 609, 626 A.2d 445. “It is the harasser’s conduct, not the plaintiffs injury, that must be severe or pervasive.” Id. at 610, 626 A.2d 445.
In sum, we are satisfied that compensatory damages for emotional distress, including humiliation and indignity resulting from willful discriminatory conduct, are remedies that require a far less stringent standard of proof than that required for a tort-based emotional distress cause of action. We hold that in discrimination cases, which by definition involve willful conduct, the victim may recover all natural consequences of that wrongful conduct, including emotional distress and mental anguish damages arising out of embarrassment, humiliation, and other intangible injuries. Accordingly, we affirm that portion of the Appellate Division’s judgment remanding for a new trial on damages.
III.
We turn now to address whether there was sufficient evidence to submit the issue of Ciasulli’s individual liability to plaintiff for sexual harassment. The Appellate Division concluded that there was sufficient evidence that Ciasulli was negligent in implementing workplace programs and policies to prevent sexual harassment. Id. at 279-80, 822 A.2d 647. Plaintiff and amicus urge that we reach that same conclusion. Ciasulli maintains that although he was plaintiffs ultimate supervisor, there was no evidence that he aided or abetted in the sexual harassment, which is a necessary requirement to impose individual liability.
N.J.S.A. 10:5-12a prohibits unlawful employment practices and unlawful discrimination by an employer. An employer “includes all persons as defined in subsection a ____ unless otherwise specifically exempt under another section of [the LAD], and [83]*83includes the State, any political or civil subdivision thereof, and all public officers, agencies, boards or bodies.” N.J.S.A. 10:5-5e. Subsection a. defines “[p]erson” as “one or more individuals, partnerships, associations, organizations, labor organizations, corporations, legal representatives, trustees, trustees in bankruptcy, receivers, and fiduciaries.” N.J.S.A. 10:5-5a. Under a plain reading of these definitions an individual supervisor is not defined as an “employer” under the LAD. Nevertheless, it is unlawful “[f]or any person, whether an employer or an employee or not, to aid, abet, incite, compel or coerce the doing of any of the acts forbidden [under the LAD],” N.J.S.A. 10:5-12e, and such conduct may result in personal liability.
We have yet to address the meaning of “aiding and abetting” under the LAD. Because the words “aid” and “abet” are not defined in the Act, the general principles of statutory construction apply. First, in interpreting the statute, we look to the “ordinary and well understood meaning” of the words therein. Safeway Trails, Inc. v. Furman, 41 N.J. 467, 478, 197 A.2d 366, cert. denied, 379 U.S. 14, 85 S.Ct. 144, 13 L.Ed.2d 84 (1964). Also, we construe words in a series consistent with the words surrounding them. Gilhooley v. County of Union, 164 N.J. 533, 542, 753 A.2d 1137 (2000).
Here, “aid” and “abet” are included with the series of words “incite,” “compel,” and “coerce.” The common dictionary definitions of these words prove helpful. Among other things, “aid” means “[t]o give help or assistance to,” Webster’s II New College Dictionary 23 (rev. updated ed.2001); “abet” means “[t]o incite, encourage, or assist, esp. in wrongdoing,” id. at 2; “incite” means “[t]o provoke to action,” id. at 560; “compel” means “to force, drive, or constrain,” id. at 229; and “coerce” means “[t]o force to act or think in a given way by pressure, threats, or intimidation,” id. at 217. All of the words used are similar in meaning and require active and purposeful conduct.
The Third Circuit Court of Appeals predicted that we would define the terms “aiding” and “abetting” consistent with the [84]*84Restatement (Second) of Torts § 876(b) (1979). Failla v. City of Passaic, 146 F.3d 149, 158 (1998) (“[W]e predict that the New Jersey Supreme Court would find that an employee aids and abets a violation of the LAD when he [or she] knowingly gives substantial assistance or encouragement to the unlawful conduct of [the] employer.”); see also Hurley v. Atlantic City Police Dep’t, 174 F.3d 95, 129 (3d Cir.1999) (predicting that New Jersey courts would impose aiding and abetting liability only on supervisory employees), cert. denied, 528 U.S. 1074, 120 S.Ct. 786, 145 L.Ed.2d 663 (2000).
Section 876(b) of the Restatement imposes concert liability on an individual if he or she “knows that the other’s conduct constitutes a breach of duty and gives substantial assistance or encouragement to the other so to conduct himself.” We agree that the Restatement provides the proper standard by which to define the terms “aid” or “abet” under the LAD. Also, the Restatement definition is consistent with the common usage of those terms. Thus, in order to hold an employee liable as an aider or abettor, a plaintiff must show that “ ‘(1) the party whom the defendant aids must perform a wrongful act that causes an injury; (2) the defendant must be generally aware of his role as part of an overall illegal or tortious activity at the time that he provides the assistance; [and] (3) the defendant must knowingly and substantially assist the principal violation.’ ” Hurley, supra, 174 F.3d at 127 (citations omitted).
With respect to that determination, the comments to section 876 provide a list of five factors, relied on by the Hurley court, to assess whether a defendant provides “substantial assistance” to the principal violator. Those factors are: (1) the nature of the act encouraged, (2) the amount of assistance given by the supervisor, (3) whether the supervisor was present at the time of the asserted harassment, (4) the supervisor’s relations to the others, and (5) the state of mind of the supervisor. Restatement (Second) of Torts, supra, § 876(b) comment d; Hurley, supra, 174 F.3d at 127 n. 27.
[85]*85Applying those factors here, we conclude that plaintiff failed to present evidence that Ciasulli aided and abetted the employees in the sexual harassment of plaintiff. There was no evidence that Ciasulli encouraged any of the wrongful conduct against plaintiff, that he assisted the wrongdoers, or that he was even present when the wrongful conduct occurred. At best, the record discloses that Ciasulli, as the supervisor in the network of auto dealerships, negligently supervised his employees. That is insufficient to conclude that he provided substantial assistance to the wrongdoers to impose individual liability under N.J.S.A. 10:5-12e. Consequently, we affirm the trial court’s dismissal of the complaint against Ciasulli.
IV.
In light of our remand for a new trial on damages, although we need not decide whether a plaintiff may be considered a “prevailing party” where the jury finds plaintiff was the victim of sexual harassment but does not award damages, for purposes of completeness and guidance in future cases we add the following.
N.J.S.A. 10:5-27.1 provides that “the prevailing party may be awarded a reasonable attorney’s fee as part of the cost.” We have cited with approval the federal view that a prevailing party is one who succeeds “ ‘on any significant issue in litigation [that] achieves some of the benefit the parties sought in bringing suit.’ ” Szczepanski v. Newcomb Med. Ctr., 141 N.J. 346, 355, 661 A.2d 1232 (1995) (quoting Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 1938, 76 L.Ed.2d 40, 50 (1983)). The United States Supreme Court has observed that “[t]he touchstone of the prevailing party inquiry must be the material alteration of the legal relationship of the parties in a manner which Congress sought to promote in the fee statute.” Texas State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782, 792-93, 109 S.Ct. 1486, 1494, 103 L.Ed.2d 866, 877 (1989) (awarding plaintiff organizations prevailing party status because judgment vindicated public employees First Amendment rights and materially altered school district’s policy).
[86]*86Subsequently, in Farrar v. Hobby, 506 U.S. 103, 113 S.Ct. 566, 121 L.Ed.2d 494 (1992), the Court analyzed the standard for awarding attorney’s fees to a prevailing party under 42 U.S.C.A § 1988. The Court defined the prevailing party status as follows:
The plaintiff must obtain an enforceable judgment against the defendant from whom fees are sought, or comparable relief through a consent decree or settlement. Whatever relief the plaintiff secures must directly benefit him at the time of the judgment or settlement. Otherwise the judgment or settlement cannot be said to “affec[t] the behavior of the defendant toward the plaintiff.” Only under these circumstances can civil rights litigation effect “the material alteration of the legal relationship of the parties” and thereby transform the plaintiff into a prevailing party. In short, a plaintiff "prevails” when actual relief on the merits of his [or her] claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.
[Id. at 111-12, 113 S.Ct. at 573, 121 L.Ed.2d at 503 (internal citations omitted) (first alteration in original).]
The Court held that a party who receives only nominal damages is still deemed to be a prevailing party in the context of awarding attorney’s fees under 42 U.S.C.A § 1988. Id. at 113, 113 S.Ct. at 574, 121 L.Ed.2d at 504. However, the Court also concluded that the nominal damages “bear on the propriety of fees awarded under § 1988,” id. at 114, 113 S.Ct. at 574, 121 L.Ed.2d at 505, because the “degree of the plaintiffs overall success goes to the reasonableness of a fee award,” ibid., 506 U.S. at 114, 113 S.Ct. at 574, 121 L.Ed.2d at 505 (citation and internal quotation marks omitted). There, the plaintiffs received one dollar in damages and the Court affirmed the denial of attorney’s fees, observing that “[a] plaintiff who seeks compensatory damages but receives no more than nominal damages” is the type of prevailing party that is entitled to “no [attorney’s] fee[s] at all.” Id. at 115, 113 S.Ct. at 575, 121 L.Ed.2d at 505-06. The Court concluded that there must be a “ ‘relationship between the extent of success and the amount of the fee award.’ ” Id. at 115-16, 113 S.Ct. at 575, 121 L.Ed.2d at 506 (quoting Hensley, supra, 461 U.S. at 438, 103 S.Ct. at 1941, 76 L.Ed.2d at 54).
We are persuaded by the reasoning of the United States Supreme Court and hold that a plaintiff who is awarded some affirmative relief by way of an enforceable judgment against [87]*87defendant or other comparable relief through a settlement or consent decree is a prevailing party under N.J.S.A. 10:5-27.1 of the LAD. Moreover, in our view, a plaintiff who is awarded nominal damages is a prevailing party under the LAD. In the case of a nominal damages award, however, we leave to the discretion of the trial court whether to award minimal attorney’s fees or no fees at all.
V.
We affirm that part of the judgment of the Appellate Division that remanded to the trial court for a new trial on damages. We reverse the judgment imposing individual liability upon Ciasulli and reverse and remand for reconsideration of the award of attorney’s fees.