ILCS » Chapter 735 · Act 110
Illinois Compiled Statutes

735 ILCS 110/25 (2026)

Attorney's fees and costs

✓ current as of May 2026
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(735 ILCS 110/25)
    Sec. 25. Attorney's fees and costs. The court shall award a moving party who prevails in a motion under this Act reasonable attorney's fees and costs incurred in connection with the motion. The court shall award a responding party who prevails in a motion under this Act reasonable attorney's fees and costs included in connection with the motion if the court finds that the motion was frivolous or filed solely with intent to delay the proceeding.
(Source: P.A. 104-431, eff. 8-21-25.)

    
Notes of Decisions
Cited in 27 cases (4 in the last 5 years), 2010–2026 · leading case: Sandholm v. Kuecker, 2012 IL 111443 (Ill. 2012).
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Sandholm v. Kuecker, 2012 IL 111443 (Ill. 2012). · cites it 3× “¶ 25 In response to defendants’ collective motion for attorney fees, the circuit court awarded fees to defendants pursuant to section 25 of the Act (735 ILCS 110/25 (West 2008)), in the total amount of $54,500.”
Wright Dev. Grp., LLC v. Walsh, 939 N.E.2d 389 (Ill. 2010). · cites it 4× “The Act seeks to extinguish SLAPPs and protect citizen participation by: (1) immunizing citizens from civil actions based on acts made in furtherance of a citizen's free speech rights or right to petition government (735 ILCS 110/15 (West 2008)); (2) establishing an expedited…”
Sandholm v. Kuecker, 962 N.E.2d 418 (Ill. 2012). · cites it 3× “¶ 25 In response to defendants' collective motion for attorney fees, the circuit court awarded fees to defendants pursuant to section 25 of the Act (735 ILCS 110/25 (West 2008)), in the total amount of $54,500.”
Hytel Grp., Inc. v. Butler, 938 N.E.2d 542 (Ill. App. Ct. 2010). · cites it 3× “” 735 ILCS 110/25 (West 2008). Hytel argues that the legislature did not intend the Act to cover persons filing “private” claims such as Butler’s wage claim, but only those persons who exercise their rights of free speech and petition in connection with an issue of public…”
Sandholm v. Kuecker, 942 N.E.2d 544 (Ill. App. Ct. 2010). · cites it 2× “As stated earlier, the trial court awarded attorney fees per section 25 of the Act (735 ILCS 110/25 (West 2008)), limiting the fees to those incurred preparing the portions of the motions to dismiss based on the Act.”
Shoreline Towers Condo. Ass'n v. Gassman, 936 N.E.2d 1198 (Ill. App. Ct. 2010). · cites it 2× “” 735 ILCS 110/25 (West 2008). The court issued three opinions with respect to fees and, ultimately, a final order awarding fees.”
Thomas v. Weatherguard Constr. Co., Inc., 2018 IL App (1st) 171238 (Ill. App. Ct. 2019). · cites it 3× “) 735 ILCS 110/25 (West 2008). Examining this statutory language, our supreme court found: “In our view, the language in section 25 is unambiguous and supports only one interpretation.”
Hammons v. Soc'y of Permanent Cosmetic Professionals, 2012 IL App (1st) 102644 (Ill. App. Ct. 2012). · cites it 2× “735 ILCS 110/25 (West 2008). The circuit court awarded $8,100 in attorney fees, limiting the defendants’ requests to a reasonable amount for the portion of the case that dealt with the application of the Act, as there is no provision for attorney fees for the defendants’ many…”
Thomas v. Weatherguard Constr. Co., Inc., 2018 IL App (1st) 171238 (Ill. App. Ct. 2018). · cites it 3× “) 735 ILCS 110/25 (West 2008). Examining this statutory language, our supreme court found: "In our view, the language in section 25 is unambiguous and supports only one interpretation.”
August v. Hanlon, 2012 IL App (2d) 111252 (Ill. App. Ct. 2012). · cites it 2× “” See 735 ILCS 110/25 (West 2010). ¶ 12 On May 16, 2011, plaintiff filed a response to defendant’s motion for summary judgment and a memorandum of law in support thereof.”
Midwest REM Enter., Inc v. Noonan, 2015 IL App (1st) 132488 (Ill. App. Ct. 2015). · cites it 3× “" 735 ILCS 110/25 (West 2010). ¶ 58 Our supreme court interpreted the Act in Sandholm v.”
In re Shelby R., 2013 IL 114994 (Ill. 2013). “Kuecker, 2012 IL 111443 , to an issue of first impression regarding attorney fees under the Citizen Participation Act (735 ILCS 110/25 (West 2008)). Although the attorney fee issue was rendered moot by our decision on the main issue, we determined that consideration under the…”
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