Illinois Supreme Court

McQueen v. Green

April 21, 2022460 Ill. Dec. 726

Summary

The court held that an employer’s admission of vicarious liability does not bar a separate claim alleging the employer’s own negligence, including negligent training or supervision. Because the employer’s independent conduct supplied a reasonable basis for liability, the verdicts finding no negligence by the employee but willful and wanton conduct by the employer were not legally inconsistent, and the trial court properly modified the principal-agent jury instruction. The court also held that the employer forfeited challenges to omitted jury instructions and that the punitive-damages award was not excessive.