Eads v. Abernathy

CourtAppellate Court of Illinois
DecidedJuly 6, 2026
Docket5-25-0039
StatusUnpublished

This text of Eads v. Abernathy (Eads v. Abernathy) 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
Eads v. Abernathy, (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (5th) 250039-U NOTICE Decision filed 07/06/26. The This order was filed under text of this decision may be NO. 5-25-0039 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT

______________________________________________________________________________

PATRICIA EADS, as Trustee of the William H. Dorman ) Appeal from the Trust, ) Circuit Court of ) Madison County. Plaintiff-Appellant, ) ) v. ) No. 22-CH-52 ) AMANDA ABERNATHY, ) Honorable ) Ronald S. Motil, Defendant-Appellee. ) Judge, presiding. ______________________________________________________________________________

JUSTICE BOLLINGER delivered the judgment of the court. Justices Boie and McHaney concurred in the judgment.

ORDER

¶1 Held: We affirm the trial court’s judgment where (1) this court does have jurisdiction to review the claims of error; (2) the trial court’s findings were not against the manifest weight of the evidence; and (3) the trial court did not err when it imposed sanctions against plaintiff pursuant to Illinois Supreme Court Rule 137.

¶2 Plaintiff, Patricia Eads, filed an action to quiet title and for other relief against defendant,

Amanda Abernathy. Plaintiff filed suit in her alleged capacity as Trustee of the William H. Dorman

Trust (Trust). The Dorman trust owns certain real estate located in Madison County, Illinois,

adjacent to defendant’s property. Plaintiff alleged that a fence erected by defendant in 2021

encroached on the Trust’s property. After a bench trial, the trial court entered judgment for

defendant, finding that plaintiff failed to sustain her burden of proof and found that her action was

1 not brought in good faith and was frivolous in nature pursuant to Illinois Supreme Court Rule 137.

Ill. S. Ct. R. 137(a) (eff. Jan. 1, 2018). The trial court ordered plaintiff to pay defendant’s attorney

fees as a sanction. Plaintiff now appeals the trial court’s judgment in favor of defendant, as well

as the order imposing sanctions. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 On November 15, 2022, plaintiff filed an action to quiet title and for other relief against

defendant. Plaintiff filed suit in her alleged capacity as trustee of the Trust that owned certain real

estate located in Madison County, Illinois, adjacent to defendant’s property. In her complaint,

plaintiff alleged that defendant “erected a lumber fence in 2021 which is exclusively on

Plaintiff[’]s property.” Defendant filed an answer to the complaint on January 17, 2023, stating

she could neither admit nor deny that plaintiff was the trustee of the Trust or that the Trust held

superior title to the property at issue. Defendant requested that the action be dismissed and she be

awarded her costs and attorney fees. The matter eventually proceeded to a bench trial on September

21, 2023.

¶5 During opening statements, defendant’s counsel explained that in November 2021, a

conflict began to arise between defendant and a Robert Dorman, who frequently maintained the

property at issue and “had a persistent habit of cutting his lawn in such a manner that threw grass

clippings, rocks and other debris” onto defendant’s property line. Defendant’s counsel continued,

stating that due to the property issue that had arisen between defendant and Dorman in November

2021, defendant extended an existing fence between the properties. Counsel claimed that

defendant had communicated with Dorman about the potential placement of the fence and that a

land survey had been done by “the Dormans” to determine the pin locations and property line at

issue. Counsel stated that the existing fence was extended based upon the property pins located

2 during that land survey but that suit had not been brought by plaintiff to adjudicate the claimed

encroachment of the fence until after a mutual injunction was entered prohibiting contact between

defendant and Dorman. Defendant’s counsel claimed that the quiet title action was brought in

retaliation and as part of the “ill-will reflected in Dorman’s actions again proven in this Court just

a week ago,” referencing an order of protection hearing involving Dorman and defendant. Counsel

asked that the trial court take judicial notice of the testimony and exhibits from the earlier order of

protection hearing.

¶6 Plaintiff called Michael Andreas as her first witness. Andreas testified that he was an

engineer “by education” and owned a consulting business called Andreas Consulting Services. He

further testified that while he was not a professional land surveyor or a land surveyor licensed and

certified with the state of Illinois, he had taken surveying courses while obtaining his degree at the

University of Illinois and had done surveying for about the past 50 years. He stated that he owned

surveying equipment in the form of a Trimble R12i, which he described as having “sub-meter

accuracy,” and that he had used GPS satellite survey systems for the past 10 years. He described

the satellite system as using satellites to “determine the elevation within sub-meter accuracy on

points and things” and stated he used such a system in this case.

¶7 Andreas testified that Robert Dorman was a friend, so at “no cost to [Dorman],” he

performed a survey of the real property at issue in this case. He stated that Dorman showed him

the property lines, that he shot the two pins, which were clearly marked by a licensed land surveyor,

and then he walked along the fence line and surveyed every post. Andreas then used AutoCAD,

which he stated “geo references all the survey points” and utilized it to draw a straight line between

the two property pins and then placed the fence along that line based on his survey of the posts.

The process generated two printout sheets, which he gave to Dorman. Andreas testified that he

3 performed the work described to the same standards and precision as he would any other job,

although he indicated that the equipment used “does the precision.”

¶8 Plaintiff moved to qualify Andreas as an expert. Defendant objected on the basis that

Andreas had testified that he was not a “professional” land surveyor, meaning he was not “certified

by industry standards to be a professional in that field.” Defendant allowed that Andreas might be

a lay witness with “significant knowledge based upon his experience” but did not believe that

expertise had been established. Plaintiff countered that the standard for qualifying a witness as an

expert was that the witness had “knowledge, training, education or experience beyond that of a

layperson” and claimed that had been clearly established as to Andreas. The trial court sustained

the objection, and declined to qualify Andreas as an expert. It did, however, allow Andreas to

continue testifying about his work based on his years of experience surveying property.

¶9 Andreas testified that, based on his survey of just the fence line, some of the fence crossed

onto the Trust’s property. This was demonstrated using a physical exhibit entered into evidence

over objection, which was a printout of the AutoCAD drawing he had made of the presumed

property line, a straight line connecting the two pins he had located, and each post of the fence

situated relative to that property line.

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Eads v. Abernathy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eads-v-abernathy-illappct-2026.