Sable Law Group, LLC v. Hatcher, 2025 IL App (1st) 241929-U

Sable Law Group, LLC was retained by Angel Hatcher in 2019 to assist with the probate estate of Sing Hatcher, later also representing Sing Hatcher, Jr. after Angel’s removal as administrator.
The firm sought attorney fees totaling $49,381.39 for services rendered from 2019 to 2024, but the court ultimately awarded $25,000.
The respondent (Sing Hatcher, Jr.) objected to the amount and basis of the fees, particularly disputing the hourly rate and necessity of certain billed tasks.
The circuit court’s decision on the fee petition was recorded only via a one-page order with no transcript or bystander’s report of the August 28, 2024, hearing.
Sable Law Group appealed the reduced fee award, arguing the trial court’s reduction was an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reducing the attorney fee was an abuse of discretion	The reduction was palpably erroneous and not based on evidence	The fee amount sought was excessive; agreement lacked details and several tasks were improperly billed	No abuse of discretion; lack of record requires presumption in favor of trial court
Whether the allowed fee was against the manifest weight of the evidence	The trial court relied solely on estate value and failed to consider all factors	The court appropriately exercised discretion based on available evidence	Same – lack of hearing record means presumption of correctness

Corral v. Mervis Industries, Inc., 217 Ill. 2d 144 (the appellate court cannot review factual findings without a record and presumes the trial court's decision is supported by the facts)
In re Marriage of Heroy, 2017 IL 120205 (defines abuse of discretion standard as a ruling that is arbitrary, fanciful, or unreasonable)
In re Marriage of Grauer, 153 Ill. App. 3d 125 (in absence of a record, courts presume trial court’s decision is well-supported)
In re Estate of Halas, 159 Ill. App. 3d 818 (explains the standard for attorney fee awards is abuse of discretion)