Lawlor v. North American Corporation of Illinois

Plaintiff filed action for intrusion upon seclusion, alleging that her former employer hired investigators to obtain her private phone records without her permission, Supreme Court recognizes the tort of intrusion upon seclusion. Evidence was sufficient to support jury's determination to award punitive damages for employer's wrongful conduct, but punitive award of ten times compensatory damages was not warranted where trial court found that conduct was de minimus on all criteria. Highest award evidence of record may support is equal to award of compensatory damages. (FREEMAN, THOMAS, GARMAN, KARMEIER, and BURKE, concurring; KILBRIDE, concurring in part and dissenting in part.)