Hytel Group, Inc. v. Butler 

Plaintiff company sued its former comptroller, alleging that she breached fiduciary duties by not preparing certain financial reports and made fraudulent misrepresentations, after Plaintiff defaulted on its loan and receivership action was filed by lender. Defendant filed motions to dismiss based on Section 2-615 and Citizen Participation Act, alleging that Plaintiff's suit was in retaliation for her filing DOL wage claim after her repeated efforts to obtain her last paycheck, alleging that company president told her that he would sue her if she filed a wage claim. Court granted motion based on the Act and awarded Defendant $34,998, which was a portion of the attorneys fees requested. Filing of wage claim is an exercise of the right to petition for redress of grievances, and is within protection of Act, which contains no "public concern" requirement. Attorneys fees award should include fees for preparation of motion for attorneys fees, but not preparation of Section 2-615 motion to dismiss. (BOWMAN and O'MALLEY, concurring.)