Saccameno v. U.S. Bank National Association (Seventh Circuit)

The Northern District of Illinois affirmed an award of $582,000 in compensatory damages and $3,000,000 in punitive damages for mishandling the plaintiff’s mortgage.  We filed an amicus brief on behalf of the Chamber of Commerce in the Seventh Circuit arguing that the district court committed several errors in applying the Supreme Court’s three guideposts for assessing the excessiveness of punitive damages.  Most notably, the court included the entire amount of compensatory damages in the denominator of the ratio guidepost even though $500,000 of those damages were for statutory and common-law causes of action that do not support an award of punitive damages.  We argue that correct application of the guideposts should result in a punitive award equal to the compensatory damages for the defendant’s punishable conduct: $82,000.