In re Marriage of Wei

CourtAppellate Court of Illinois
DecidedMay 19, 2023
Docket1-12-21371
StatusUnpublished

This text of In re Marriage of Wei (In re Marriage of Wei) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Marriage of Wei, (Ill. Ct. App. 2023).

Opinion

2023 IL App (1st) 1221371-U FIFTH DIVISION May 19, 2023 No. 1-22-1371

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 ______________________________________________________________________________ In re MARRIAGE OF ) Appeal from the Circuit Court WEI WEI, ) of Cook County. ) Petitioner, ) ) and ) No. 2019 D 005469 ) PENG LIU, ) ) Respondent-Appellant ) ) (The Law Office of Tiffany M. Hughes, ) Honorable ) Regina A. Scannicchio, Petitioner-Appellee). ) Judge, presiding. 1

PRESIDING JUSTICE DELORT delivered the judgment of the court. Justices Mitchell and Lyle concurred in the judgment.

ORDER

¶1 Held: In this marriage dissolution case, we hold that the circuit court correctly entered a fee award against the husband and in favor of his former attorney, even though the court

1 Pursuant to Illinois Supreme Court Rule 330 (eff. July 1, 2017), we have corrected the caption in this matter and hereby direct the clerk of this court to correct the docket accordingly. 1-22-1371

had not referred the fee dispute to alternative dispute resolution, because the husband had affirmatively opted out of such alternative dispute resolution.

¶2 Respondent Peng Liu challenges the circuit court’s order requiring him to pay about $3,400

in attorney fees to his former lawyer who represented him in his divorce case. Liu contends that

the circuit court erred by considering his former lawyer’s fee petition without referring the dispute

to mediation or arbitration, which he argues is required by section 508(c)(4) of the Marriage and

Dissolution of Marriage Act. 750 ILCS 5/508(c)(4) (West 2018). We affirm.

¶3 BACKGROUND

¶4 Wei Wei and Peng Liu were married in 2007. On June 25, 2019, Wei petitioned the circuit

court for dissolution of marriage, citing irreconcilable differences that have caused the irretrievable

breakdown of their marriage.

¶5 On March 12, 2020, Liu retained the Law Office of Tiffany M. Hughes (Hughes) to

represent him in the dissolution proceedings. The retainer agreement he signed included a

statement of his rights and responsibilities, and it explained the procedure for fee disputes in

dissolution cases under section 508(c)(4) of the Marriage and Dissolution of Marriage Act. 750

ILCS 5/508(c)(4) (West 2018). Section 508(c)(4) requires that, in the event of a controversy over

fees, parties must first seek alternative dispute resolution, such as mediation or arbitration.

¶6 Liu paid most of Hughes’ requested attorney fees throughout the proceedings. However, a

portion remained outstanding. On August 13, 2021, Hughes filed a petition in the circuit court to

recover the outstanding fees. The petition was periodically continued, and the matter proceeded to

a hearing.

¶7 On April 7, 2022, the circuit court conducted a trial on various other issues pending in the

dissolution proceedings, but appears it did not address the fee petition that day. The issues

2 1-22-1371

addressed included child support, custody, maintenance, and property distribution. The transcript

of the trial does not appear in the record of this appeal. But it does appear in the record of a related

appeal, in which Liu challenges the circuit court’s later disposition of the issues litigated at the

trial.2

¶8 On April 8, 2022, the court ordered both parties to submit closing arguments and proposed

judgments as to the issues litigated during the trial, and continued the matter to June 6, 2022.

¶9 On April 11, 2022, the circuit court issued a written order. In relevant part, the court stated

that “[Liu] agrees to waive his right to a contribution hearing and Mediation of Attorney’s Fees

and costs relating to The Law Office of Tiffany M. Hughes’ Petition for Final Attorney’s Fees and

Costs Against Client Pursuant to 508(C) and For Other Relief.” (Capitalization in original). It is

not clear from the record what prompted the April 11, 2022 order.

¶ 10 On August 1, 2022, the circuit court entered an exhaustive order of dissolution

summarizing the evidence adduced at the trial. The order addressed, among other things, child

support, retroactive child support, custody, maintenance, and property distribution. It appears that

the August 1 order resolved all outstanding issues except for the fee petition at issue in this appeal.

The trial order also contained a finding pursuant to Illinois Supreme Court Rule 304(a) (eff. Mar.

8, 2016) that there was no just cause to delay enforcement or appeal thereof.

¶ 11 On August 8, 2022, the circuit court resolved the last remaining issue—the fee petition—

and ordered Liu to pay Hughes her requested fees of $3,452.75 within 45 days. This hearing was

held via videoconference, but Liu has not submitted a transcript of these proceedings for our

2 In the related appeal docketed as no. 1-22-1336, Liu challenges the circuit court’s dissolution judgment that was issued about a week before the court’s decision on the fee petition in this appeal. Today, we issue a contemporaneous Rule 23 order disposing of that appeal.

3 1-22-1371

review. On September 7, 2022, Liu filed his notice of appeal challenging the circuit court’s August

8 order requiring him to pay Hughes.

¶ 12 ANALYSIS

¶ 13 On appeal, Liu argues that the circuit court erred by failing to refer the attorney fee dispute

to alternative dispute resolution, as required by section 508(c)(4) of the Marriage and Dissolution

of Marriage Act. 750 ILCS 5/508(c)(4) (West 2018).

¶ 14 At the outset, we note that the petitioner-appellee, the Law Office of Tiffany M. Hughes,

has not filed a responsive brief. However, the record is relatively simple, and the claimed errors

are such that we can easily decide them without the aid of the appellee’s brief. See First Capital

Mortgage Corp. v. Talandis Construction Corp., 63 Ill. 2d 128, 133 (1976). We need not reverse

simply because the petitioner-appellee failed to file a brief.

¶ 15 Liu filed a notice appeal of the August 8, 2022 fee judgment on September 7, 2022. Since

he filed the notice of appeal within 30 days of the fee judgment, and nothing else remained pending

at the time, the fee judgment was a final and appealable order, and we have jurisdiction to consider

this appeal.

¶ 16 Section 508(c)(4) reads, in relevant part,

No final hearing under this subsection (c) is permitted unless any controversy over fees

and costs (that is not otherwise subject to some form of alternative dispute resolution) has

first been submitted to mediation, arbitration, or any other court approved alternative

dispute resolution procedure, except as follows:

(A) In any circuit court for a single county with a population in excess of 1,000,000, the

requirement of the controversy being submitted to an alternative dispute resolution

4 1-22-1371

procedure is mandatory unless the client and the counsel both affirmatively opt out of

such procedures…” 750 ILCS 5/508(c)(4) (West 2018).

¶ 17 Liu’s retainer agreement contained a description of his rights, which included an

explanation of the 508(c)(4) procedure. Pursuant to section 508(c)(4)(A), Liu must have

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In re Marriage of Wei, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-marriage-of-wei-illappct-2023.