GOE Global Enterprises, Inc. v. Mindful Healthcare Agency, Inc.

2026 IL App (1st) 250278-U
Appellate Court of Illinois·Decided February 10, 2026·No. 1-25-0278·Unpublished

Opinion

2026 IL App (1st) 250278-U No. 1-25-0278

Order filed February 10, 2026 SECOND DIVISION

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS FIRST DISTRICT

)

GOE GLOBAL ENTERPRISES, INC., )

) Appeal from the Circuit Court Plaintiff-Appellee, ) of Cook County )

v. ) No. 2023L009333 )

MINDFUL HEALTHCARE AGENCY, INC., ) Honorable ) Patrick J. Sherlock, Defendant-Appellant. ) Judge Presiding.

JUSTICE D.B. WALKER delivered the judgment of the court.

Justices McBride and Ellis concurred in the judgment.

ORDER

¶1 Held: Illinois law governs the contract in question, and the circuit court did not err in awarding fees and costs to plaintiff. We affirm.

¶2 In the underlying case, GOE Global Enterprises, Inc. (Plaintiff) sought to recover the payment owed to it by Mindful Healthcare Agency, Inc. (Defendant) pursuant to a contract between the two under which plaintiff provided accounting services to defendant. By convenient coincidence, just after defendant received the benefit of plaintiff’s services, it discovered that the provision in the contract under which it was to pay plaintiff was

prohibited by regulation in Massachusetts, where defendant is domiciled. Defendant refused to pay for plaintiff’s services and plaintiff sued. The circuit court ruled in plaintiff’s favor on summary judgment, finding that there was no genuine issue of material fact and that Illinois law applied. As a result, defendant was obligated to uphold its end of the contract and pay plaintiff the promised fee. Plaintiff also successfully sought to recover fees and costs from defendant. On appeal, defendant challenges both orders, alleging that Massachusetts law should control, that the circuit court impermissibly failed to determine whether the amount owed to plaintiff was a reasonable contingent fee, and that the court should not have awarded plaintiff fees and costs. We disagree, and we affirm the circuit court’s order.

¶3 I. BACKGROUND

¶4 The facts of this case are undisputed, except where we specifically note otherwise. Defendant is a Massachusetts-based corporation that provides home healthcare services in that state. Plaintiff, which is incorporated in and maintains its primary place of business in Illinois, offered its services to defendant for the purpose of submitting the necessary forms to the Internal Revenue Service to obtain employee retention credit (ERC) tax refunds for defendant. There is disagreement between the parties’ factual accounts as to whether plaintiff’s agent approached defendant to solicit its business or whether defendant’s agent inquired with plaintiff about its services. Regardless, the parties negotiated and signed the contract (the Agreement) at the heart of this dispute.

¶5 The Agreement estimated that defendant would receive $1,940,000 as a result of plaintiff’s efforts. It dictated that defendant would pay plaintiff $485,000 “as professional fees for services rendered hereunder *** upon receipt of any portion of the ERC amount.”

The Agreement further stated: “In the event the IRS does not pay ERC to [defendant], [plaintiff] agrees to waive the afore-referenced professional fees.”

¶6 The contract was clear about the parties’ intentions as to the applicable law, stating:

“If any term or provision of this Agreement is invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other term or provision of this Agreement or invalidate or render unenforceable such term or provision in any other jurisdiction.

***

All matters arising out of or relating to this Agreement or the transactions contemplated hereby shall be governed by and construed in accordance with the internal laws of the State of Illinois without giving effect to any choice or conflict of law provision or rule (whether of the State of Illinois or any other jurisdiction).

***

“In the event that [plaintiff] institutes any legal suit, action, claim, demand, or proceeding, including arbitration, against [defendant] in respect of a matter arising out of or relating to this Agreement, [plaintiff] shall be entitled to receive, in addition to all other damages to which it may be entitled, the costs incurred by [plaintiff] in conducting such suit, action, claim, demand, or proceeding, including its reasonable attorneys’ fees and expenses, court costs and arbitration fees.”

¶7 Defendant received an ERC tax refund, but the amount and circumstances are unclear due to defendant’s bizarre handling of the facts surrounding the refund. Plaintiff asserted in its complaint that its services resulted in it filing amended tax filings for defendant and defendant receiving “more than $1,768,647.00” from the IRS. Defendant answered this

allegation with the unclear statement: “It states the complaint speaks for itself. It denies the remaining allegations.” Plaintiff alleged that it submitted specific documents to the IRS reflecting that defendant was entitled to that refund. Defendant answered by stating that “it has no knowledge sufficient to form a belief as to the truth of the allegations in that paragraph.” Plaintiff alleged that “[a]s a result of Plaintiff’s services, Defendant received the benefit of the Refund from the IRS in the amount of $1,768,647.00, or substantially all of that amount.” Defendant answered, stating that “[i]t admits that it received a refund as a result of Plaintiff’s services. It denies the remaining allegations.” Plaintiff alleged that “[b]ut for Plaintiff’s advisory and accounting consulting services, Defendant would not have received all, or substantially all, of the $1,768,647.00 from the IRS.” Defendant denied that allegation. In its answer, defendant raised the affirmative defense that the Agreement was “unethical, illegal, and unenforceable pursuant to 252 Mass. Code Regs. § 3.03.”

¶8 Plaintiff filed a request to admit that clarified the matter. In it, plaintiff presented a series of statements that it submitted Form 941-X tax documents to the IRS on defendant’s behalf and that defendant received various amounts of money from the IRS as a result. Through its responses, defendant asserted that it did receive $1,768,647.00 from the IRS, but it did not know if the payment was a result of plaintiff’s efforts because plaintiff refused to provide any documents that it submitted to the IRS on defendant’s behalf, and because defendant was unable to learn through reasonable inquiry whether the payment was a result of such efforts on plaintiff’s part. Defendant deposited “at least one check” from the IRS but denied any knowledge of whether it was connected with plaintiff’s efforts. Defendant, in its subsequent filings, including its response to plaintiff’s motion for summary judgment and its appellate brief, has assiduously avoided stating that it received a refund at all, even when discussing

plaintiff’s alternative theory of unjust enrichment, while simultaneously admitting that plaintiff did perform services for it. This is a glaring omission in defendant’s factual account and in its briefs when defense counsel could easily comply with its duty of candor by acknowledging the refund received from the IRS, as it did in its pleadings, while still questioning that the resulting refund was due to plaintiff’s efforts. That said, it is difficult to believe that defendant could not, with reasonable effort, obtain information from the IRS regarding its own tax filings, even if plaintiff was uncooperative. Thus, we see no reason for this simple statement of fact to be so elaborately and tacitly contentious, while also being admitted in the pleadings.

¶9 A. Summary Judgment

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GOE Global Enterprises, Inc. v. Mindful Healthcare Agency, Inc., 2026 IL App (1st) 250278-U (Ill. Ct. App. 2026).

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