Eads v. Abernathy

Appellate Court of Illinois·Decided July 6, 2026·No. 5-25-0039·Unpublished

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

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

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

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. Andreas testified that eight feet of the fence encroached upon the Trust property, and the encroachment ranged from one-tenth of a foot to a half-foot. Andreas also indicated that there were portions of the fence that were as much as a foot over the property line. Andreas estimated that about 90% of the fence was over the property line and on the Trust’s side, with only about six feet of the fence being on the defendant’s side.

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Eads v. Abernathy, (Ill. Ct. App. 2026).

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