In re Parentage of Z.B.M., 2024 IL App (1st) 231988-U

1. Case citation and parties
- In re Parentage of Z.B.M., 2024 IL App (1st) 231988-U (Ill. App. Ct., 1st Dist., Apr. 9, 2025) (Rule 23 order).
- Plaintiff-Appellant: Marc Bushala. Defendant-Appellee: Rebecca Joy McAdams. Appellee claimant for fees: law firm Rosenfeld/Farmer (R/F).

2. Key legal issues
- Whether the Illinois Parentage Act of 2015 precludes a contribution claim for final attorney fees sought by an attorney who represented a party.
- Whether the trial court abused its discretion in awarding R/F $453,430.38 in final attorney fees and ordering contribution from Marc, given alleged lack of an explicit finding that the fees were reasonable.

3. Holding/outcome
- Affirmed. The appellate court held that the Parentage Act does not prohibit a contribution award for final attorney fees requested by a party’s attorney, and the trial court did not abuse its discretion in awarding the fees and contributions. The fee award at issue was $453,430.38.

4. Significant legal reasoning
- Standard of review: fee awards are reviewed for abuse of discretion. The appellate court emphasized deference to the trial court’s familiarity with the lengthy, complex parentage litigation (multi-day trial and multi-day fee hearing).
- Statutory interpretation: the court rejected appellant’s contention that the Parentage Act bars contribution to final attorney fees requested by counsel, finding no statutory prohibition.
- Record sufficiency on reasonableness: the trial court had the engagement agreement, detailed billing records, time entries, and live testimony from R/F attorneys explaining tasks and hourly rates. The court considered parties’ financial affidavits and prior interim fee rulings. Although settlement communications were excluded under Rule 408, the court allowed an offer of proof; exclusion did not render the fee determination unreasonable. The appellate court concluded the factual record adequately supported the trial court’s findings and fee computation.

5. Practice implications (concise)
- Preserve and produce detailed engagement agreements, contemporaneous time entries, billing statements, and live witness testimony on rates and tasks — these are decisive in defending fee petitions.
- In parentage litigation, fee contribution claims (including final fee petitions by counsel) are permissible; litigants should address statutory arguments early and present clear financial affidavits to support ability/inability to pay.
- Expect appellate deference to trial courts on fee reasonableness where the court is factually familiar and the record contains documentary and testimonial support.
- Be mindful that Rule 408 will likely exclude settlement offers as evidence of reasonableness; use other evidence (market rates, complexity, time spent) to justify fees.