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$50,000 in sanctions against an Illinois association's lawyer were vacated on a filing technicality

Illinois · Courts

$50,000 in sanctions against an Illinois association's lawyer were vacated on a filing technicality

What happened. On August 19, 2025 the Illinois Appellate Court, First District, Second Division, vacated and remanded more than $50,000 in Rule 137 sanctions against an association's attorney in Goodman Chicago Condos, LLC v. Atrium Court Village Home Condominiums, 2025 IL App (1st) 232329-U. It is a Rule 23 order and is not precedential.1

What the circuit court found

After an evidentiary hearing, the circuit court found that the attorney had fabricated an email purportedly from the condominium association president, and sanctioned him.

Why the sanctions were vacated

On a narrow ground: Rule 137 reaches only documents actually filed with the court, and the brief containing the fabricated email was never filed with the clerk.

The appellate court was pointed about what it was and was not doing. The disposition is “only on technical grounds, however important that technicality,” and it expressly remanded for the circuit court to consider other remedies for the fabricated email — and to reach three further allegations of fraud it had not decided.

The practice point

Rule 137 does not reach documents exchanged between counsel but never filed. That is a real and sometimes surprising limit, and it is the holding practitioners will cite.

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  1. Goodman Chicago Condos, LLC v. Atrium Court Village Home Condominiums, 2025 IL App (1st) 232329-U (Rule 23 order, August 19, 2025) ↩

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