When considering whether to impose sanctions under Rule 137, the "attorney's conduct must be judged by an objective standard." Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 48, 123 N.E.3d 1271. The party requesting the imposition of Rule 137 sanctions bears the burden of proof.

'The failure to provide proper citations to the record is a violation of Rule 341(h) (7), the consequence of which is the forfeiture of the argument.'" Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 43, 123 N.E.3d 1271. However, where the appellate court finds the flaws were not "so serious as to interfere with [the appellate court's] ability to understand and adjudicate [the] case," the court may address the issue presented.

On review, a circuit court's denial of a motion for attorney fees and costs pursuant to Rule 137 or section 508(b) will not be overturned absent an abuse of the circuit court's discretion. Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 49, 123 N.E.3d 1271; In re Marriage of Michaelson, 359 Ill.App.3d 706, 715, 834 N.E.2d 539, 547 (2005). A court "abuses its discretion when no reasonable person would agree with its decision."

That argument, however, presents a separate issue—whether the court erred in allowing counsel's withdrawal. Not only is that issue forfeited due to the failure to raise it before the trial court (see Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 38, 123 N.E.3d 1271 ("[i]ssues not raised before the trial court are deemed forfeited and may not be raised for the first time on appeal")), it is also forfeited due to his failure to provide any meaningful argument with citation to supporting legal authority on appeal (see Ill. S. Ct. R. 341(h)(7) (eff. Oct. 1, 2020)

Significantly, the trial court noted that Pliura only proceeded on the good faith argument and voluntarily withdrew his public use argument after it was rejected in Kuerth, 2018 IL App (4th) 150519-B. Pliura acted reasonably when he withdrew his public use argument, which this court recently rejected in Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ___ N.E.3d ___. Rule 137 is to be strictly construed, and the purpose of the rule is to prevent frivolous lawsuits, not to punish unsuccessful litigants. Peterson, 313 Ill. App. 3d at 7.

But the construction of a statute and the trial court's assessment of its own continuing jurisdiction are both purely legal matters affecting how a broad category of cases will proceed. See id. ¶ 43 (construction of a statute); Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 26 (trial court's jurisdiction). Rita P. is strong precedent for our finding that the requirements for the public interest exception to the mootness doctrine are met here.

Ill. S.Ct. R. 341(h)(7) (eff. Oct. 1, 2020) (Points not argued in the appellant's brief "are forfeited and shall not be raised in the reply brief, in oral argument, or on petition for rehearing."); People v. Aljohani, 2022 IL 127037, ¶ 61, 211 N.E.3d 325 (stating Rule 341(h)(7) "requires an appellant to adequately develop his argument with citation of relevant authority" and that the failure to do so results in forfeiture of the issue); Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 43, 123 N.E.3d 1271 (stating an appellant's failure to properly cite to the record on appeal violates Rule 341(h)(7) and results in forfeiture of the appellant's argument). Further, "[t]he fact that a party appears pro se does not relieve that party from complying as nearly as possible to the Illinois Supreme Court Rules for practice before this court."

He should have raised the issue of the invoices being redacted before the trial court and not for the first time on appeal. See Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 38, 123 N.E.3d 1271 ("Issues not raised before the trial court are deemed forfeited and may not be raised for the first time on appeal.").

¶ 23 "Forfeiture applies when an issue is not raised in a timely manner." Enbridge Pipeline, LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 38. "Issues not raised before the trial court are deemed forfeited and may not be raised for the first time on appeal." Hoke, 2019 IL App (4th) 150544-B, ¶ 38.

(Internal quotation marks omitted.) Enbridge Pipeline (Illinois), LLC v. Hoke, 2019 IL App (4th) 150544-B, ¶ 43, 123 N.E.3d 1271. The trial record in this case is voluminous, and we would be warranted in finding plaintiff's damages claim forfeited based upon his failure to properly support his claim with pertinent citations to the appellate record.