Punitive Damages and Real Estate Fraud – Some Illinois Legal Guideposts

In K2 Development, LLC v. Braunstein, 2013 IL App (1st) 103672-U, the First District addressed Illinois law’s compensatory and punitive damages guideposts in a convoluted real estate fraud suit filed by an LLC against one of its two members. The plaintiff LLC – through one of its members (a real estate novice) – sued the LLC’s other member – an experienced real estate developer – for fraud in connection with the defendant’s sale of an undeveloped piece of land to the plaintiff. The court awarded compensatory damages of nearly $400K and punitive damages of over $750K after a bench trial and the defendant appealed. Held: Affirmed. Rules/reasoning: The Court upheld the trial court’s damage awar

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