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Grauer v. Clare Oaks, et al, 2019 IL App (1st) 180835, is noteworthy to all counsel who regularly encounter fee-shifting statutes in their practice. Grauer was borne out of a verdict against a nursing home, but the court’s analysis as to the reasonableness of attorney’s fees and what constitutes “costs” in the context of the Illinois Nursing Home Care Act is important to all practitioners.

The Nursing Home Act provides that “the licensee shall pay the actual damages and costs and attorney’s fees to a facility resident whose rights” under the Act are violated. 210 ILCS 45/3-602. The rationale for

Continue Reading No “Costs” Uncovered: The Appellate Court’s Expansive Redefinition of “Costs”