Gray v. Hampshire Holdings, LLC
2025 IL App (3d) 230665-U
Ill. App. Ct.2025Background
- Catherine Gray was injured in a Home Depot by a flower cart pushed by an employee of a temp agency for Hampshire Holdings, LLC in 2019.
- Three days post-incident, Catherine Gray retained Robert A. Langendorf, P.C. (Langendorf) under a contingency fee agreement; she later discharged Langendorf and retained new counsel (TPMB).
- Catherine passed away from unrelated causes, and her daughter, Janelle Gray, was appointed administrator of her estate and continued the injury suit.
- The estate ultimately settled the case for $150,000, with $50,000 allocated to attorney’s fees.
- Langendorf asserted a lien for fees based on quantum meruit for work done prior to being discharged; the trial court awarded $1,015 based on 2.9 hours at a $350/hour rate.
- Langendorf appealed, arguing for a higher fee and challenging the trial court’s calculations and evidentiary choices.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether the trial court properly calculated attorney fees under quantum meruit | Langendorf did not provide sufficient documentation to justify more hours; award was reasonable. | Langendorf argued he should be paid for all hours claimed, at an hourly rate he asserted ($500/hr), based on his skill and experience. | Court found the awarded 2.9 hours at $350/hour was reasonable and supported by the evidence. |
| Whether the trial court erred in not expressly addressing all quantum meruit factors (including skill, standing) | The trial court made appropriate implicit findings and is not required to detail each factor. | Langendorf argued the trial court ignored his higher skill level and customary fee as an arbitrator. | Not required to list each statutory factor; court implicitly considered all factors and its reasoning stands. |
| Proper hourly rate and location for fee determination | Use the customary rate in Du Page County, where litigation occurred. | Langendorf argued for Cook County rates, where his office and most practice was located. | Court appropriately used Du Page County rates, based on location of services/litigation. |
| Reliance on documentary evidence over testimony to determine hours worked | Documentary evidence is more credible; Langendorf’s estimates were unsupported by records. | Langendorf argued his testimony should suffice to support more hours billed. | Circuit court correctly credited documentary evidence and limited testimony, consistent with its role. |
Key Cases Cited
- Will v. Northwestern University, 378 Ill. App. 3d 280 (Ill. App. Ct. 2007) (discharged contingency attorneys are entitled to reasonable compensation in quantum meruit)
- In re Estate of Callahan, 144 Ill. 2d 32 (Ill. 1991) (burden of proof on attorney for value of services)
- Forest Preserve District of Cook County v. Continental Community Bank Trust & Co., 2017 IL App (1st) 170680 (factors for reasonable attorney compensation considered under quantum meruit)
- Wildman, Harrold, Allen & Dixon v. Gaylord, 317 Ill. App. 3d 590 (Ill. App. Ct. 2000) (review of attorney fee award is for manifest weight of evidence)
- In re Marriage of Malec, 205 Ill. App. 3d 273 (Ill. App. Ct. 1990) (attorney fee awards should be based on rates in the court where services were rendered)