In re Marriage of Bedard, 2024 IL App (1st) 232280-U

Full Case Summary

In the case of In re Marriage of Matthew Bedard and Solange Fingal Bedard (2024 IL App (1st) 232280-U), the Illinois Appellate Court addressed sanctions imposed on attorney Lori M. Succes during the dissolution of marriage proceeding between her former client, Solange Fingal Bedard, and her spouse, Matthew Bedard. The case, filed on September 30, 2024, involves a highly contentious legal battle where multiple filings and allegations of improper conduct were exchanged between the parties.

Lori Succes had represented Solange from October 2022 to April 2023. After Succes withdrew, the circuit court sanctioned her for making what were deemed meritless and duplicative filings. The court initially laid out the basis for sanctions, which included several motions related to maintenance, parenting time, and the appointment of a Guardian ad Litem (GAL).

The court found that while the sanctions were justified concerning various filings predating December 1, 2022, Succes was not given adequate notice about sanctionable conduct related to some filings made after that date. Consequently, the appellate court upheld some of the sanctions but vacated those related to the later filings due to lack of notice.

Ultimately, the majority of the circuit court's sanctions against Succes were upheld, amounting to nearly $36,000, though the court allowed for objections regarding the conduct occurring after December 1, 2022. The appellate court emphasized the importance of proper notice in sanction proceedings while affirming that the circuit court's rulings on earlier filings were within the bounds of discretion.

The case illustrates the complexities of legal representation in high-conflict divorces, the responsibilities of attorneys to avoid frivolous filings, and the procedural safeguards necessary in sanctioning legal professionals.