Midwest Sanitary Service, Inc. v. Sandberg, Phoenix & Von Gontard, P.C.

Summary

The Illinois Supreme Court held that Illinois’ statutory prohibition on punitive damages in legal‑malpractice actions (735 ILCS 5/2‑1115) and public policy do not bar recovery of punitive damages that a client actually paid in an underlying case when those damages are proximately caused by the attorney’s negligence; such damages are treated as compensatory. The court affirmed the appellate court and remanded for further proceedings.