Guarantee Trust Life Insurance Company, an Illinois Corporation, Petitioner v. the Estate of Michael Dean Casper…

Summary

The court held that the plaintiff’s death after the jury verdict did not reduce the damages awarded on his contract, statutory insurance-benefits, bad-faith, or punitive-damages claims. Attorney fees and costs awarded under section 10-3-1116(1) constitute actual damages and therefore properly count toward the punitive-damages calculation. The court nevertheless held that the trial court improperly entered final judgment nunc pro tunc because those fees and costs had not yet been fixed.