Enbridge Pipeline (Illinois), LLC v. Hoke

Plaintiff pipeline company filed easement condemnation action against landowners who then filed traverse motions. Trial court sanctioned landowners' attorney, finding that memorandum he filed, on remand, was not objectively reasonable and was filed solely to delay. Trial court had jurisdiction to sanction counsel on remand. Rule 137 always applies to all matters properly before the trial court. Court did not abuse its discretion in sanctioning counsel under Rule 137. A condemning authority is not required to provide more than 10 days for negotiations to satisfy good-faith requirement. (HOLDER WHITE and TURNER, concurring).