Illinois Appellate Court
Civil Court
Trusts and Estates
Plaintiff was beneficiary of a living trust. Plaintiff filed complaint against trust’s attorney. Court imposed sanctions against plaintiff and awarded attorney fees to trust’s attorney, who appeared pro se. Court properly dismissed tortious interference claim as barred by doctrine of res judicata. Court did not abuse its discretion in finding tortious interference claim was filed for an improper purpose under Rule 137. However, trust’s attorney was not entitled to collect attorney’s fees where he did not incur such fees while appearing pro se. (HALL and ROCHFORD, concurring.)