In Kabbe v. Miller (1990) 226 Cal. App. 3d 93, the court denied respondent's request for sanctions even though the appeal lacked merit. "We do not believe it is appropriate to hold a propria persona appellant to the standard of what a 'reasonable attorney' should know is frivolous unless and until that appellant becomes a persistent litigant." ( Id. at p. 98.) The majority opinion explained its reasoning: "We recognize a litigant appearing in propria persona is generally held to the same restrictive rules and procedures as an attorney. However, we have found no case imposing sanctions on a propria persona appellant solely on the ground the appeal lacked merit. In each case the court has found some impropriety in addition to lack of merit to support the imposition of sanctions. In some cases the court found the appeal was brought for the purpose of delay. Because Ms. Kabbe is the plaintiff in this action, delay is not a factor here." ( Id. at p. 98.) The majority concluded that mere lack of merit does not justify the imposition of sanctions against a pro se litigant. However, Justice Lillie wrote a concurring and dissenting opinion arguing forcefully that sanctions are appropriate where, in addition to filing a meritless appeal, the litigant also makes unsupported accusations of conspiracy, judicial misconduct, and unprofessional behavior of respondent and his counsel. (Id. at pp. 101-102 (conc. & dis. opn. of Lillie, P.J.).)