Saccamento v. U.S. Bank National Assn

Record failed to contain sufficient evidence to support jury’s $3 million punitive damages award in claim under Ill. Consumer Fraud and Deceptive Practices Act, alleging that defendant made several attempts to collect on debt that had been discharged in plaintiff’s Chapter 13 bankruptcy petition. Record showed that: (1) defendant sent plaintiff several notices that made false claims that plaintiff owed defendant money and threatened plaintiff with foreclosure of her home; and (2) when plaintiff challenged defendant’s claims, defendant failed to explain why it believed that plaintiff owed it money. While defendant asserted that any punitive damages award was improper, since any errors were made by single employee, record showed that defendant essentially ratified actions of said employee, where it continued to defend actions of said employee through its course of litigation, and where no one at defendant took any steps to investigate how employee’s erroneous actions occurred or how they could have been prevented. However, $3 million punitive damages figure set by jury was excessive, and Ct. reduced said figure to $582,000, which constituted 1 to 1 ratio with compensatory damages award set by jury.