Dombrowski v. Larson Lodge

Plaintiffs are Illinois attorneys who were discharged by their Illinois resident client who filed a wrongful death action in Florida against Water Mania, Inc. (defendant). They brought an action in an Illinois circuit court against the defendant in the underlying personal injury case to enforce their attorney’s lien for fees. Defendant specially appeared to contest in personam jurisdiction of the Illinois courts. The trial court quashed service of process and dismissed plaintiffs’ cause of action. Plaintiffs appealed.

The issues presented for review are (1) whether plaintiffs have waived their…