JUSTICE MYERSCOUGH delivered the opinion of the court:

In October 2002, plaintiff, Negro Nest, LLC., doing business as Servpro ofSpringfield (Servpro), filed suit against defendant, Mid-Northern Management, Inc. (Mid-Northern),seeking payment for services rendered pursuant to a contract. In November 2003, the parties settledon the amount owed for the services provided but reserved the issues regarding interest, attorneyfees, and costs for the trial court's determination. In March 2004, the trial court entered judgmentin Servpro's favor, awarding $15,659.87 in attorney fees, costs, and interest.

On appeal, Mid-Northern argues the trial court erred in its award because (1) theparties' contract did not specifically provide a basis for awarding attorney fees and (2) the feesawarded were unreasonable. Because we agree with the first point, we reverse.

I. BACKGROUND

In February 2002, ServPro entered into a contract with Mid-Northern by whichServpro was to perform cleaning and restoration services on a multiunit apartment complex managedby Mid-Northern. The contract was prepared by ServPro and included a provision stating, "If theundersigned fails to pay for services rendered and collection efforts become necessary, theundersigned agrees to be responsible for all collection costs incurred." (Emphasis added.) Servproperformed pursuant to the contract and sent Mid-Northern an invoice for $7,860.66.

Between February and September 2002, Servpro sent six invoices to Mid-Northern. Mid-Northern did not pay the bill. In October 2002, Servpro filed suit seeking $8,744.50 plusinterest, reasonable attorney fees, court costs, and all costs of collection. The parties settled inNovember 2003 for the full amount of the original invoice, $7,860.66, and the remaining issuesregarding interest, attorney fees, and costs were left to be determined by the trial court.

In March 2004, the trial court heard oral arguments on the issues. The primary pointof contention was whether the contract provision providing for "all collection costs" allowed Servproto collect for its attorney fees. The trial court held attorney fees are encompassed within "allcollection costs." The court entered judgment in Servpro's favor, awarding $12,668.75 in attorneyfees, $524.27 costs, and $2,467.85 interest for a total of $15,659.87. This appeal followed.

Mid-Northern first contends the trial court erred in awarding attorney fees to Servprobecause the court incorrectly found "all collection costs" included attorney fees.

A. Standard of Review

The construction of a contract is a question of law, and the standard of review is denovo. Pennsylvania Life Insurance Co. v. Pavlick, 265 Ill. App. 3d 526, 529, 637 N.E.2d 1160, 1162(1994).

B. Illinois Is an American Rule Jurisdiction

Illinois follows the "American Rule," which provides that absent statutory authorityor a contractual agreement, each party must bear its own attorney fees and costs. Morris B. Chapman& Associates, Ltd. v. Kitzman, 193 Ill. 2d 560, 572, 739 N.E.2d 1263, 1271 (2000). Statutespermitting the recovery of costs are in derogation of the common law and must be strictly construed. Calcagno v. Personalcare Health Management, Inc., 207 Ill. App. 3d 493, 502, 565 N.E.2d 1330,1336 (1991). Similarly, contractual provisions providing for attorney fees should also be strictlyconstrued. Helland v. Helland, 214 Ill. App. 3d 275, 277-78, 573 N.E.2d 357, 359 (1991). Successful litigants cannot recover attorney fees as costs unless expressly authorized by a statute oragreement using specific language. See Estate of Downs v. Webster, 307 Ill. App. 3d 65, 70, 716N.E.2d 1256, 1260 (1999).

A statute or contract must allow for attorney fees by specific language, such that onecannot recover if the provision does not specifically state that "attorney fees" are recoverable. SeeDowns, 307 Ill. App. 3d at 70, 716 N.E.2d at 1260; Qazi v. Ismail, 50 Ill. App. 3d 271, 273, 364N.E.2d 595, 596-97 (1977).

C. Seventh Circuit Boulevard Bank Opinion

The contract provision at issue calls for recovery of "all collection costs." Thecontract makes no mention of attorney fees. Plaintiff asks this court to include attorney fees underthe umbrella of "collection costs."

Plaintiff relies exclusively on a Seventh Circuit case, Boulevard Bank National Ass'nv. Philips Medical Systems International B.V., 15 F.3d 1419 (7th Cir. 1994), which held "collectioncosts" included attorney fees under Illinois law. The Boulevard court distinguished the generalprinciple that attorney fees are not recoverable unless explicitly authorized by written contract, onthe basis that those prior courts had only been construing the term "costs" alone, and not whenmodified by another term such as "collection." Boulevard, 15 F.3d at 1426. The court reasoned thatto give effect to the term "collection costs" it was necessary to include attorney fees, the major costincurred, and that if the parties wanted to exclude attorney fees they would have used the word"costs" alone. Boulevard, 15 F.3d at 1426. The court found the term "collection" modified the term"costs" in such a way as to allow recovery under the contract. Boulevard, 15 F.3d at 1426. Incoming to this conclusion, the court relied on Meeker v. Fowler, 35 Ill. App. 3d 313, 341 N.E.2d 412(1976), which interpreted "collection charge" under section 20 of "An Act in relation to retailinstallment sales" (Ill. Rev. Stat. 1965, ch. 121 1/2, par. 243) (hereinafter 1965 Act) to includeattorney fees.

D. Meeker: An Anomaly Caused by the Interplay of Contracts

and Statutory Penalty Provisions

In Meeker, the parties signed numerous instruments, during two transactions in 1965and in 1968, representing the transfer of three grain bins. The trial court found each transactionconstituted an installment sales contract that was governed by the version of the act in effect at theinception of each contract. Ill. Rev. Stat. 1965, ch. 121 1/2, pars. 223 through 253; Ill. Rev. Stat.1967, ch. 121 1/2, pars. 501 through 533 (hereinafter 1967 Act). The trial court found the sellernoncompliant with the acts and implemented sanctions under two provisions, including denying theseller recovery of his attorney fees because the court believed the fees constituted a "collectioncharge," forfeited under one of the statutory penalty provisions. The appellate court reversed the trialcourt in part, finding the 1968 transaction did not fall within the 1967 Act, but also remanded thecause for a determination of whether the 1965 transaction fell within the 1965 Act. Meeker, 35 Ill.App. 3d at 320-21, 341 N.E.2d at 417-18. The court, in dicta, went on to address whether, if the1965 transaction did fall within the 1965 Act, the seller could be denied recovery of his attorney feesas a statutory penalty for his noncompliance.

Section 20 of the 1965 Act stated in part, "[a]ny person violating [certain provisionsof the Act] *** is barred from recovery of any finance charge, delinquency[,] or collection charge*** on the retail installment contract involved." Ill. Rev. Stat. 1965, ch. 121 1/2, par. 243. Theseller contended the trial court erred in denying him recovery for his attorney fees as a "collectioncharge" under the provision. In support, the seller pointed to section 6 of the Act, which allowed theholder of the contract to include contract provisions allowing for recovery of delinquency andcollection charges as well as reasonable attorney fees in the instance of default. Ill. Rev. Stat. 1965,ch. 121 1/2, par. 228. The seller argued "collection charge" in section 20 should not be interpretedto encompass attorney fees because the legislature clearly treated collection charges separately fromattorney fees in section 6. The Meeker court rejected this argument, finding section 6 only appliedwhen holders in compliance with the law were seeking to recover under their contracts. Meeker, 35Ill. App. 3d at 321-22, 341 N.E.2d at 418-19.

The Meeker court emphasized the buyers were trying to recover under an additionalstatutory penalty provision, section 17, which allowed a monetary penalty plus recovery of thebuyer's attorney fees if the seller failed to comply with the provisions of the act. Meeker, 35 Ill. App.3d at 322, 341 N.E.2d at 419. Assuming the contract fell under the 1965 Act, the seller's violationswould result in (1) the seller's forfeiture of any finance, delinquency, and collection charges; (2) amonetary penalty against the seller equal to the contract finance charge or 10% of the purchase price;and (3) the seller's payment of the buyer's attorney fees. Meeker, 35 Ill. App. 3d at 322, 341 N.E.2dat 419; Ill. Rev. Stat. 1965, ch. 121 1/2, pars. 240, 243. Given the penalty provisions and the seller'sviolation of the law, the court concluded it would be ironic to allow the seller to recover his attorneyfees. Meeker, 35 Ill. App. 3d at 322, 341 N.E.2d at 419.

In support, the Meeker court stated, "[t]hough the question seems not to have beenconsidered in Illinois, we find authority from other jurisdictions to the effect that 'collection charge'includes attorney's fees." Meeker, 35 Ill. App. 3d at 322, 341 N.E.2d at 419, citing Ben ConstructionCorp. v. Snushall, 254 N.Y.S.2d 948, 44 Misc. 2d 878 (1964); General Finance Co. v. Powell, 114Mont. 473, 138 P.2d 255 (1943); McClain v. Continental Supply Co., 66 Okla. 225, 168 P. 815(1917). The Meeker court was attempting to give effect to the penalty provision within the contextof the entire 1965 Act but in doing so, interpreted statutory language to include attorney fees absentexpress language. We find Meeker unpersuasive in the present case and contrary to prevailingIllinois law.

E. Authorities Underpinning Meeker

As already noted, Meeker relied on authority from three other American Rulejurisdictions in reaching its conclusion. At issue in Ben Construction Corp., 254 N.Y.S.2d 948, 44Misc. 2d 878, was a penalty provision in an act governing retail installment contracts. The plaintiffwas seeking liquidated damages and attorney fees pursuant to a contract provision allowing for suchin the event of defendant's breach. Ben Construction Corp., 254 N.Y.S.2d at 950, 44 Misc. 2d at880. The trial court found the plaintiff noncompliant with the governing act and applied the act'spenalty provision. Ben Construction Corp., 254 N.Y.S.2d at 951, 44 Misc. 2d at 881. The courtdenied the plaintiff recovery, finding the damages and attorney fees were forfeited as delinquencyand collection charges pursuant to the act. Ben Construction Corp., 254 N.Y.S.2d at 952, 44 Misc.2d at 881.

In General Finance Co., 114 Mont. at 475, 138 P.2d at 256, at issue was a guarantycontract providing for "'all collection expenses.'" The court held attorney fees were recoverable asa collection expense because the plaintiff was forced to file suit to collect. General Finance Co., 114Mont. at 481, 138 P.2d at 258. The General Finance Co. court relied on Wood v. Ferguson, 71Mont. 540, 230 P. 592 (1924), an earlier Montana case. General Finance Co., 114 Mont. at 481, 138P.2d at 258. Wood held the negotiability of a note providing for "'attorney's fees and all costs ofcollection'" was not destroyed even though the governing statute only allowed for "'costs ofcollection or an attorney's fee.'" (Emphases in original.) Wood, 71 Mont. at 549, 230 P. at 594,quoting Rev. Codes 1921,