7th Circuit - Sanctions It's the holiday season so please accept this case as my present to you. A knucklehead attorney (how many of us know one) apparently grieved how his town operated and decided to take action. The opinion illustratively begins: Eberhardt has a history with the Village of Tinley Park and its officials. At last count, he has filed more than 25 lawsuits, 14 ethics complaints, and 150 Freedom of Information Act requests since 2014, the vast majority of which have been dismissed. In one of those dismissed cases, the judge "put[] Eberhardt on notice" that his litigation strategy was nearly sanctionable, as Eberhardt seemingly did not "appreciat[e] the need for substantive legal support for his claims." Eberhardt v. Seaman, No. 17 L 11231 (Cir. Ct. Cook Cnty. Sep. 28, 2018) (Dkt. 153-4, Ex. C, at 19-20). Undeterred, Eberhardt continued filing frivolous lawsuits. In 2020, the attorney filed another lawsuit including claims against he town attorney. That claim was dismissed and the town attorney sought sanctions and: The district court denied Eberhardt's hearing request and granted Walsh's Rule 11 motion, ordering Eberhardt to pay Walsh $26,951.22 in attorneys' fees. The district court found Eberhardt's claims were "frivolous" and "brought with inadequate investigation into the relevant law and facts." The district court explained that Eberhardt's claims had three fundamental legal flaws: a lack of facts establishing the court's subject-matter jurisdiction; a lack of injury-in-fact based on Walsh's appointment; and a lack of evidentiary support that Walsh was appointed in violation of the Village's Purchasing Ordinance. At bottom, the district court found "Eberhardt sued Walsh, alleging little action and no injury, for violations of Village ordinances that were not violations at all." The panel affirmed. Eberhardt vs. Walsh, processWebInputExternal.pl<https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2024/D12-05/C:23-1770:J:Pryor:aut:T:fnOp:N:3302212:S:0> Sign up for the IMLA Kitchen Sink the best way to keep up with current legal issues affecting local government. www.imla.org<http://www.imla.org> Charles W. Thompson, Jr. Of Counsel P: (202) 466-5424 x7110 M: (240) 876-6790 D: (202) 742-1016 [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [logo]<https://imla.org/> 51 Monroe St. Suite 404 Rockville, MD, 20850 www.imla.org<http://www.imla.org/>