PRESIDING JUSTICE CHAPMAN delivered the opinion of the court:

Joe Heidlebaugh was born with severe cerebral palsy and spastic quadriplegia, andhe has severe motor disabilities. When Joe was one year old, he was abandoned and placedin foster care. Approximately 10 years later, John and Darlene Heidlebaugh, a deeplyreligious couple from southern Illinois, saw Joe on a television program and felt called toadopt him. It took the Heidlebaughs a year to locate Joe, but they persevered, and in 1982,when Joe was 13 years old, they adopted him.

The Heidlebaughs cared for Joe during his minority. They sent him to specialeducation classes, and he graduated from that school in 1991. In addition to his physicaldisabilities, Joe is limited mentally. In Dr. Levinson's opinion, his development is far belowage five. Joe was subsequently enrolled in a workshop located in West Frankfort, whichFranklin-Williamson Human Services (FWHS) operated. A bus or van took Joe to theworkshop in the morning and brought him home late in the afternoon. Joe's brother, Dexter,also has serious disabilities, and he attends the workshop along with Joe.

On the morning of May 22, 1996, Joe Heidlebaugh's parents, John and DarleneHeidlebaugh, placed him on the bus so that he could be taken to the workshop he had beenregularly attending for five years. Joe did not get off the bus that evening. Instead, thedriver of the bus handed Darlene a note that said Joe would not be coming home. No onetold John or Darlene where Joe had been taken. This case is about the necessity of sanctionsfor the conduct involved in these and related actions.

John Heidlebaugh is appealing from the trial court's denial of his motion forsanctions under Supreme Court Rule 137 (155 Ill. 2d R. 137). He contends that the trialjudge (1) abused his discretion in declining to sanction Karen Kauffman and the twoadditional attorneys employed by Equip for Equality, Inc. (EFE), and (2) erred in finding helacked the authority to sanction EFE. For the reasons that follow, we affirm in part andreverse in part, and we remand to the trial court the issue of the determination of the amountof fees and sanctions.

For some time before April 1996, the community support coordinator for FWHS hadbeen speaking with the Heidlebaughs about placing Joe in a group home. TheHeidlebaughs' response was always that they were able to take care of Joe but that if at sometime in the future they were no longer able to do so, they would have a family discussionabout placing Joe in a group home.

The Heidlebaughs received a letter from FWHS notifying them of a meeting to beheld at 10 a.m. on April 11, 1996. The letter stated that the purpose of the meeting was "[t]odiscuss Joe's services at Franklin-Williamson County and his goals for the future." However, an internal document, which was not furnished to the Heidlebaughs, stated thatthe purpose of the meeting was "[t]o discuss Joe moving out of current living situation intoCILA home." Because the Heidlebaughs could not attend the meeting on that date, theyspoke with an individual at FWHS and asked for the meeting to be rescheduled. Themeeting was not rescheduled and was conducted in the Heidlebaughs' absence.

On May 22, 1996, Joe, without notice to the Heidlebaughs, filed a petition for anorder of protection against the Heidlebaughs. In that petition, Joe identified himself as a"high risk adult with disabilities" as defined in the Illinois Domestic Violence Act of 1986(750 ILCS 60/101 et seq. (West 1996)). The petition alleged that the Heidlebaughs hadphysically neglected Joe by not assisting him with proper hygiene. In addition, it allegedthat the Heidlebaughs limited Joe's fluid intake and put Joe in his bedroom whenever he wasnot at the workshop. It is undisputed that at no time before the filing of this petition for anorder of protection had anyone from FWHS or EFE contacted Joe's parents to inform themthat there was any problem or concern about any of the problems alleged in the petition. Thepetition also stated that Joe had been given temporary shelter at a location known to hiscaregivers. That location was not disclosed to the Heidlebaughs, although later it was foundto be Independence Place and then Pathway House. The petition asked for an orderprohibiting the Heidlebaughs from contacting Joe. The petition further alleged that the harmwhich the order of protection was intended to prevent "would be likely to occur ifrespondent were given any prior notice." Alan Rankin of FWHS signed the petition on theline provided in the petition for an attorney's signature.

The circuit court granted the order and stated that it would be in effect until 1:30 p.m.on June 10, 1996, when there would be a hearing. Darlene and John were served withcopies of the order. Together they filed a pro se appearance on May 28. They requested anextension because their attorney was out of town. On June 6, 1996, Katherine Black filedher appearance for the Heidlebaughs.

On June 10, 1996, a hearing was called before Judge Phillip Palmer on the order ofprotection. At that time, Karen Kauffman, an attorney employed by EFE, successfullymoved for her appointment as independent counsel to represent Joe's interests. EFE is anonprofit corporation designated by the State of Illinois as the protection and advocacyagency for developmentally disabled persons. When she was appointed, Karen Kauffmanstated to the court that she was very familiar with the background of the case. TheHeidlebaughs' attorney had no objection to the appointment, and she presented a motion fora continuance so that counsel could conduct discovery and have Joe examined by apsychologist. In addition, the parties agreed that the temporary order of protection wouldbe continued pending the hearing. Also on June 10, John filed a petition to be appointedJoe's guardian. EFE, represented by Karen Kauffman, opposed the petition. On July 11,Judge Paul Murphy entered a 30-day interim order of protection. That order expired August17, and subsequently the judge entered a docket entry stating that it had expired.

On September 27, 1996, both John's guardianship petition and EFE's counterpetition,which asked that the court appoint the Office of State Guardian as Joe's guardian, werecalled for a hearing before Judge Murphy. A three-day evidentiary hearing was held, withtestimony from psychologists, physicians, family and friends, Joe's parents, and Joe'scaregivers from both the workshop and the group home.

The evidence completely destroyed any argument that Joe was capable of makingchoices for himself. In addition, although credible evidence of Joe's less-than-optimal levelof cleanliness was presented, there was absolutely no credible evidence of abuse, of Joebeing kept locked in his room for all his time at home, or of Joe being improperly limitedas to the amount of food and drink he could have. In short, there was absolutely no evidencethat any order of protection was ever required. In addition, neither Alan Rankin nor anyother employee of FWHS who testified had ever spoken with John and Darlene about thealleged substandard level of care he was receiving at their home prior to the petition beingfiled. Finally, the evidence established that when Joe was taken from John and Darlene,Pathway House began receiving well over $2,000 per month from the state for Joe's supportwhile he lives there. In addition, Pathway House received Joe's SSI and Social Securitychecks.

At the close of the evidence, Judge Murphy orally chastised both FWHS and EFE formany of the actions taken during both the order of protection and the guardianshipproceedings. On October 10, Judge Murphy issued his ruling in letter form. The letterstated the court's intention to appoint John as Joe's guardian, and again the judge chastisedthe agencies for their actions. On November 7, the order appointing John as guardian wasentered, and John removed Joe from the group home. On December 3, Steven Mills andJanet Cartwright, attorneys employed by EFE, filed an entry of appearance as cocounsel forJoe and a motion for the modification of the order appointing John guardian. On December23, John filed a notice of appeal from the denial of the motion for attorney fees that he hadfiled in both the order-of-protection case and the guardianship proceeding. The appellatecourt dismissed both appeals because of the lack of an appealable final order. After somefurther orders were filed in the trial court, John again appealed from the denial of his motionfor sanctions.

This case presents the question of whether the trial court's refusal to impose sanctionswas an abuse of discretion. The sanctions were sought (1) against an attorney of record, (2)against EFE, an employer of that attorney, who, it is argued, could also be considered as anattorney of record or a party, and (3) against two attorneys also employed by the sameemployer who had minor involvement at the end of the proceedings.

Rule 137 states that both the parties and the attorneys have an affirmative duty toconduct an inquiry of the facts and the law before filing an action, pleading, or other paperand that the failure to make such an inquiry could subject them to sanctions. 155 Ill. 2d R.137; see Amadeo v. Gaynor, 299 Ill. App. 3d 696, 700, 701 N.E.2d 1139, 1142-43 (1998). The rule requires a party or litigant to (1) sign pleadings and other papers to certify that heor she has read the document, (2) make reasonable inquiry into its basis, (3) believe that itis well-grounded both in fact and in law or that there is a good-faith argument for theextension, modification, or reversal of existing law, and (4) not interpose it for any improperpurpose, such as harassment, unnecessary delay, or needless increase in the cost of thelitigation. 155 Ill. 2d R. 137.

The purpose of Rule 137 is to prevent the abuse of the judicial process by penalizingthose who bring vexatious or harassing actions without sufficient foundation. Amadeo, 299Ill. App. 3d at 701, 701 N.E.2d at 1143. This rule is penal in nature and must be strictlyconstrued. Amadeo, 299 Ill. App. 3d at 701, 701 N.E.2d at 1143. A trial court's decisionwhether to impose sanctions will not be reversed absent an abuse of discretion. Amadeo,299 Ill. App. 3d at 701, 701 N.E.2d at 1143. This standard of review, however, does notprevent the appellate court from independently reviewing the record and finding an abuseof discretion if the facts so warrant. Walsh v. Capital Engineering & Manufacturing Co.,312 Ill. App. 3d 910, 914, 728 N.E.2d 575, 578-79 (2000).

FWHS notified Karen Kauffman of Joe's situation on April 11, 1996. She met withJoe on April 17. On May 22, Joe, with the help of Alan Rankin, filed the "pro se" petitionfor order of protection. Karen Kauffman argued in her brief that she did not become"attorney of record" until June 10, when she was appointed. However, she began acting asJoe's counsel the moment she began advising him, and FWHS, of what steps to take in thiscase in mid-April. The Heidlebaughs' attorney acknowledged this fact by providing serviceto Karen Kauffman on June 5, prior to her appointment as Joe's counsel. Even KarenKauffman, herself, acknowledged her prior involvement in the case when she explained tothe court upon being appointed Joe's counsel that she was very familiar with the case. Thesefacts support the conclusion that Karen Kauffman was acting as the attorney when theoriginal petition for order of protection, with its numerous misstatements of fact, was filed.

What could FWHS have done instead of filing for an emergency order of protection? What alternative methods were available that they could have been advised of by KarenKauffman? It could have been advised to tell Joe's parents of their concern about hishygiene and the other problems. It could have been advised that Joe's parents should be toldthat the April 11 meeting was to discuss moving Joe. It could have been advised that, ifJoe's parents were unwilling to cooperate, a petition to appoint a guardian would be filed. Apparently, FWHS was advised of none of these alternatives and was instead advised to filefor an emergency order of protection that accused Joe's parents of the following: "Respondent has engaged in physical neglect such as not assisting petitioner with properhygiene, [wheel]chair unwashed, clothing soiled by feces, ears have been found to be dirty. Petitioner has been limited by respondent in terms of fluid intake. Respondent has putpetitioner in bedroom for all of hours outside of Franklin-Williamson workshop." Inaddition, the petition prayed for an order prohibiting Joe's parents from committing any ofthe following: physical abuse, willful deprivation, harassment, neglect, interference withpersonal liberty, exploitation, and stalking.

The only act of misconduct contained in the preprinted petition that Joe's parentswere not prohibited from committing was the intimidation of a dependent. Apparently thiswas eliminated so that EFE could be consistent in its position that, since Joe had not beenthe subject of a guardianship proceeding, he was presumed competent to make all his ownchoices and to file for an order of protection on his own.

The trial court's conclusion about the use of this procedure is instructive:

"This case was flawed from the start. It began in the courts with a Petition forOrder of Protection alleging domestic abuse by the parents, John and DarleneHeidlebaugh, against their alleged disabled adult son Joe in [No.] 96-OP-133. Theallegations, prepared by Alan Rankin as attorney for Joe C. Heidlebaugh andpurportedly signed and sworn by Joe himself, included allowing Joe to sit in hissoiled pants, isolating Joe for 18 hours per day in his bedroom[,] and denying himwater. These allegations under oath certainly cried out for judicial intervention[,]and[] without notice to his parents, said parents were ordered to stay away from Joe. The problem was [that] the allegations turned out to be substantially unfounded.

Based upon misstatements of fact, Joe's parents were denied any knowledgeof his whereabouts for three weeks[,] during which time they retained counsel, filedfor guardianship herein[,] and appeared in [No.] 96-OP-133.

The real theory behind the actions of counsel for Equip for Equality, Inc., andthe actions of the various care provider entities before and after May 22, 1996, thedate of the petition for order of protection, was not abuse of Joe by his parents[] butJoe's assumed ability to control his destiny by making his own choices as to wherehe wanted to live, without assistance of parent or guardian. Joe, it is argued, is 27,and adult, and is untethered by quaint notions of family ties, even though he needshelp with everything. These same care providers had many times before soughtconsent from these same parents. The parents were informed of their change in statusfirst by a bus driver handing them a message, 'Joe's not coming home today[]', andlater by service of the Order of Protection.

Thus, the strategy of pursuing the Order of Protection was exposed, at trial ofthis cause, as nothing less than a premeditated preemptive strike at the parents bycounsel and Mr. Rankin because they knew that when they acted on one's 'choice' tomove away from home[,] that [sic] the parents would not sit still for it. They knewthat the law would be needed to block John and Darlene from the exercise of theirrights in the matter. They knew that the exercise of any other legal option other thanan Order of Protection by those seeking to remove Joe would have required priornotice to the parents. Said prior notice (a/k/a 'due process of law' in our constitution)would have triggered Ms. Black's appearance and prevented a finding of abuse in theOP case.

The abuse that occurred here was abuse of process and abuse of the purposefor which orders of protection are allowed. It is shocking that in the pursuit of therespect of rights for the disabled and the handicapped that professional persons andcare providers so sensitive to such rights could so consciously steamroll the rights ofthe parents.

The notion that Joe Heidlebaugh should be presumed to be a free agentcapable of managing his own affairs is simply preposterous. Both physicians in thiscase agree he functions mentally like a three[-] or four[-]year[-]old. That rationaladults with access to his medical and social history and his everyday life experiencescould conclude they had the superior right[,] without the blessing of a court, to assistJoe in 'firing' his parents, and in changing his doctor, his religious practices, hisresidences, his money, his diet, etc., manifests a colossal audacity. ***

*** But that was just the beginning of this travesty. Attorney Kauffman atevery stage of these legal proceedings resisted Ms. Black's attempts to obtain medicalrecords which the parents themselves were responsible for creating[] and which sheknew or should have known were relevant to this case. She did not counterpetitionthat anyone else be appointed Joe's guardian until the day of trial. Court[-]orderedmedical appointments were postponed more than a month without good cause orleave of court first obtained. Procedural roadblocks were strewn in Ms. Black's pathto the obvious truth: that Joe is mentally incompetent and needs a guardian.

The testimony of Dr. Smith totally destroyed the abuse theory. Dr. Smith'sviews were made available to Joe's care providers in writing. The reaction? Getanother doctor!! Dr. Levinson's testimony and that of Dr. Smith made laughable thenotion that poor Joe can think for himself without a guardian. A 'visuallychallenged' judge could see that in a minute. Ms. Black's cross[-]examinationeviscerated any notion that the motives of Ron Mertz and Alan Rankin were pure.

It is not that respondent's witnesses don't care for Joe. They obviously do! It is their arrogant attitude to the parents that has them in trouble. Not to mentiontheir arrogant attitude to the courts! Fine when the court, without notice to parents,helps them take Joe from his family. But when that same court is used to seekmedical records on behalf of the parents to prove the obvious fact that their disabledson is in fact disabled, then and only then do they have to get a lawyer to postpone,to obscure, to delay said discovery and to intimidate those seeking to use this courtto get to the truth. They should seek to hide those records because those recordsexpose the weakness of the legal theory on which they based their actions (abuse byJohn and Darlene, and legal competence of Joe)[,] as well as the degree of theirpremeditation. The court has seldom witnessed more devastating use of records tocross[-]examine witnesses that [sic] was done by Attorney Black in this case.

Only after some brilliant work by Ms. Black does respondent belatedly arguethat, yes, Joe does need a guardian. But[] it is further argued he needs a guardianwho will ratify their misdeeds. The Court is belatedly directed by Attorney Kauffmanto consider all the 'good' things that have happened to Joe since he's been away fromhome. Joe loves the whirlpool at the group home, they say. Joe loves the familyatmosphere at the group home. Joe is so upset about what the Court might do. Howdoes he know so much about the Court? Why did he want so badly to talk to thejudge? Whose interests does it serve to keep him upset about it? Certainly not JohnHeidlebaugh's. Where was this group home and where were these care givers 15years ago when John Heidlebaugh sought out Joe-then abandoned by his own birthparents and languishing in a foster home? For the crime of not being the best caregiver-parent in the area, John is given a legal lynching by those who ought to knowbetter." (Emphasis in original.)

What was the effect of this petition for an order of protection and the order that allowed it? The effect was to remove Joe from the home of his parents, parents who had spent a yearsearching for him in order to adopt him and another year in the adoption process. Theseparents, who had adopted a severely disabled child and raised him for the next 14 years,were not informed of (a) any problem with Joe's hygiene or any of the other allegedproblems set out in the petition or (b) the true purpose of the April 11, 1996, meeting, whichwas, of course, to take Joe from them and put him in a group home. They were not evengiven the courtesy of a phone call from Mr. Rankin or anyone from FWHS. Instead, theywere handed a note by the bus driver, and that was that. Their son was gone; they knewnothing more, neither where nor why.

What was the effect of this action? According to the uncontroverted testimony, it wasdevastating both to Joe's parents and to Joe. Because his parents were forbidden to contacthim, Joe felt they had abandoned him.

This travesty did not end with the entry of the order of protection; it continuedthroughout these proceedings. For example, after Joe's parents were informed of hislocation at Pathway House, Joe's father went to visit him, and obviously, they were happyto see one another after a separation of almost four months. Joe's father told the people atPathway House that he would be back the next day to see his son. When he returned, he wastold that they had checked with the lawyer, and he would not be allowed to see his son ona daily basis, but only once a week. John told them he would return the following week andhe did, and again he was turned away. This time he was told that he should have called thatday to tell them he was coming to visit. This episode in September should be coupled withcertain activities in April that were testified to by Alan Rankin, the FWHS representative. Mr. Rankin testified that in April 1996, Karen Kauffman had checked out the existence ofa possible guardianship over Joe in several jurisdictions and had told him that there werenone. In addition, he testified that in either April or May 1996, Karen Kauffman hadadvised Joe of his rights. These incidents in April and/or May 1996 strongly suggest thatKaren Kauffman was acting as Joe's attorney before her appointment on June 10, 1996. TheSeptember incident equally strongly suggests that her involvement in preventing Joe'sparents from seeing him continued well past the time the court had allowed visitation.

Another statement by the trial court about the conduct of Karen Kauffman and EFEmay be appropriate at this point:

"The nub of this petition[-]for[-]fees[-]and[-]sanctions case is that AttorneyKauffman and Equip for Equality, Inc., acted in a high[-]handed manner in pursuitof what they perceived as Joe's rights. They arrogantly presumed the very issue tobe decided: Joe's capacity to decide matters for himself.

In their self-righteousness they initiated legal proceedings against Joe'sparents. In theory, they were acting as Joe's lawyer. Funded by others, they causedJoe's parents to expend thousands of dollars to defend a position the parents had heldfor years without benefit of the Courts: that of Joe's guardian.

Either or both Equip for Equality, Inc., and Attorney Kauffman concluded thatthey had the ability, sua sponte[] (or upon the instructions of a 26[-]year[-]old withthe admitted mental capacity of below five years old)[,] to hold themselves out asJoe's lawyer. As to Ms. Kauffman, as a lawyer she is presumed to be familiar withethical Rule 7.3(b)(1)[,] and under the facts of this case, under Rule 137 she probablycould be sanctioned for violating it.

'(b) In no event may a lawyer solicit a prospective client if:

(1) the lawyer reasonably should know that the physical or mental stateof the person is such that the person could not exercise reasonablejudgment in employing a lawyer.' [134 Ill. 2d R. 7.3(b)(1).]

Furthermore, there was stealth in the way they proceeded. They waited untilJoe was away from home. They filed for an Emergency Order of Protection, on veryweak grounds, and thereby wrested physical control of Joe from his parents. Whilelitigation was pending about Joe's competence, they again presumed the issue to bedecided by directing Joe's money from his parents to other care providers without aidof Court.

Until the day of trial, Attorney Kauffman and Equip for Equality[] resisted thenotion that Joe lacked capacity to decide things for himself. Joe's incapacity(physical and mental) is so patently obvious that no trier of fact could possiblyconclude that Joe is not incapacitated, that he is not in need of a guardian.

Thus only after needless and expensive pre[]trial maneuvering did AttorneyKauffman finally agree at trial that Joe needed a guardian but it should be someoneother than his parents. The medical evidence presented overwhelming [sic] favoredJoe's parents. Nothing approaching abuse or justifying removal of Joe from hisparents was apparent from the evidence presented.

Attorney Kauffman defends her actions as zealous representation of her client. The fact that she is employed by an organization established to protect the interestsof the disabled does not empower her to file appearances on behalf of anyone shechooses. Because she is an advocate for the disabled, it was illogical and surprisingthat she steadfastly maintained, in the face of overwhelming evidence, that Joe hadthe capacity to retain her, to choose where he would live, who should get to spend hismoney, etc. He obviously had no such mental capacity. Her proper course was torepresent a person or entity willing to be Joe's guardian and to seek their appointmentas guardian. By claiming to be Joe's lawyer directly[,] she bypassed such niceties asdue process and fact finding, not to mention the probate act, and the implied primaryrights of a parent in such situations."

The trial court's disapproval of the conduct of Karen Kauffman and EFE is clearlyapparent from the excerpts of the letter orders we have quoted. Why then did the trial courtrefuse to enter sanctions? With regard to EFE, the trial court specifically stated:

"Assuming the Court had the authority to sanction Equip for Equality, Inc., itwould not hesitate to do so. *** But Rule 137 is for lawyers and does not apply tothem."

Although we are cognizant of the trial court's concern that it was unable to sanctionEFE because EFE was neither a lawyer nor a party, we conclude that the court was not sopowerless for several reasons. First, the driving force behind all these proceedings was EFE. The face of the petition for the order of protection lists only Joe Heidlebaugh as thepetitioner. Theoretically, only Joe could be sanctioned as a party, but Joe quite clearly didnot have the mental capacity either to frame the allegations of the petition or to choose thatmethod of proceeding. Who was the real party in charge of the proceedings? When thisrecord is viewed in its entirety, it is clear that the entity in charge, both in the order ofprotection proceeding and in the guardianship proceeding, was EFE. Who represented EFE? Karen Kauffman.

John Heidlebaugh contends not only that EFE was the entity in charge but also thatEFE should be estopped from contending that it was not acting as an attorney because EFErepeatedly asked to be recognized as counsel. On June 10, 1996, Karen Kauffman filed amotion for appointment of independent counsel in which she set out EFE's position as anadvocacy agency for developmentally disabled persons and then asked: "WHEREFORE,EQUIP FOR EQUALITY, INC., by Karen Odell Kauffman, respectfully moves that Equipfor Equality, Inc. be appointed independent counsel for Joe E. Heidlebaugh, a high risk adultwith disabilities." (Emphasis added.) In addition, there are several pleadings signed byKaren Kauffman that begin, "Comes now Joe C. Heidlebaugh through Equip for Equality,Inc., by Karen Odell Kauffman, and moves this court to ***." Finally, on July 2, 1996,Karen Kauffman stated in a motion to strike, "[T]he only contact or involvement by KarenOdell Kauffman or Equip for Equality, Inc. with any of the parties to this action has beenas pro bono legal counsel to Petitioner, Joe C. Heidlebaugh." (Emphasis added.)

In view of EFE's request to be appointed counsel and its repeated filing of pleadingsin which it appeared to be acting as counsel, the estoppel argument is persuasive, but weconclude that EFE is subject to sanctions under Supreme Court Rule 137 because of itsposition as Karen Kauffman's employer. A principal is liable for the acts of its agentcommitted within the scope of her authority. Brubakken v. Morrison, 240 Ill. App. 3d 680,608 N.E.2d 471 (1992). Brubakken upheld the entry of sanctions against the law firm thatemployed the lawyer who committed the sanctionable conduct. Similarly, we conclude thatEFE is responsible as principal for the sanctionable conduct of its agent, Karen Kauffman.

Next, we turn to the trial court's refusal to impose sanctions on Karen Kauffman. The trial judge gave two reasons for his reluctance to sanction Karen Kauffman, eventhough he strongly disapproved of her conduct. First, he felt that her actions were motivatedby a good-faith, zealous representation of her client. Second, he felt that her youth andinexperience mitigated against the imposition of sanctions.

Good faith alone is not a defense to sanctionable conduct. An objective standard ofreasonableness based upon the entirety of the circumstances must be applied. In reMarriage of Irvine, 215 Ill. App. 3d 629, 638, 577 N.E.2d 462, 468 (1991).

Judge Murphy stated, "By claiming to be Joe's lawyer directly, [Karen Kauffman]bypassed such niceties as due process and fact finding, not to mention the probate act, andthe implied primary rights of a parent in such a situation." Such actions could not have beentaken if she had made a reasonable inquiry into whether they were well grounded in fact andlaw or as a good-faith argument for the change of existing law.

Even if the reasonable-inquiry requirement could have been met when the petitionswere originally filed, it could not be met after the evidence was presented. Rule 137contains an implicit requirement that an attorney promptly dismiss a lawsuit once it becomesevident that it is unfounded. See Cmarko v. Fisher, 208 Ill. App. 3d 440, 446, 567 N.E.2d352, 355 (1990). A violation of this continuing duty of inquiry is sanctionable. Once KarenKauffman recognized that, as Judge Murphy stated, "[n]othing approaching abuse orjustifying removal of Joe from his parents was apparent from the evidence presented," shehad a duty to dismiss the petition for the appointment of guardian or else she risked thepossibility of sanctions.

Also, although it is true that courts have taken age and experience into consideration,in this case we believe that it is improper to deny sanctions solely on that basis. Most often,courts rely on this youth-and-inexperience defense in disciplinary proceedings. However,none of Karen Kauffman's sanctionable conduct appears to be because of mistakes ofjudgment made by a neophyte lawyer. First, by 1996 she had been licensed for five or sixyears. In addition, the conduct consists of specific maneuvers, stealthily accomplished, inan attempt to further the goals of the agency. Therefore, for the aforementioned reasons, weconclude that the trial court abused its discretion in denying John's motion for sanctionsagainst Karen Kauffman.

We recognize that a trial court has discretion in determining whether sanctions shouldbe applied. The discretion, however, is not unlimited, and a number of cases have reversedthe denial of sanctions by the trial court. Pritzker v. Drake Tower Apartments, Inc., 283 Ill.App. 3d 587, 670 N.E.2d 328 (1996); Fremarek v. John Hancock Mutual Life InsuranceCo., 272 Ill. App. 3d 1067, 651 N.E.2d 601 (1995); Wittekind v. Rusk, 253 Ill. App. 3d 577,625 N.E.2d 427 (1993).

On appeal, a contention that is supported by some argument but absolutely no legalauthority does not meet the requirements for consideration. In re Tally, 215 Ill. App. 3d 385,390-91, 574 N.E.2d 1262, 1265 (1991). John's argument for the sanctioning of StevenMills and Janet Cartwright lacks any authority whatsoever. Therefore, we conclude thatJohn's argument does not merit consideration, and we affirm the trial court's denial ofsanctions against them.

CONCLUSION

For the above reasons, we affirm the judgment of the trial court with regard to StevenMills and Janet Cartwright, and we reverse with regard to Karen Kauffman and EFE. Weremand to the trial court for a determination as to the amount of fees and sanctions to be paidby Karen Kauffman and EFE.

HOPKINS and GOLDENHERSH, JJ., concur.