On December 1, 2005, the Illinois Appellate Court, Fourth District, reversed the decision of the Circuit Court of Menard County, which held that a contract provision stipulating that the defendant management company would be responsible for "all collection costs" allowed recovery for attorney's fees.

Effective January 1, 2006, the Illinois general Assembly amended the Attorney Act, 705 ILCS 205/1 et seq, by changing section 1. 

On September 22, 2005, the Illinois Supreme Court reversed the judgment of the Illinois Appellate Court, First District.