Saccameno v. U.S. Bank National Association

943 F.3d 1071 (2021)

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Saccameno v. U.S. Bank National Association

United States Court of Appeals for the Seventh Circuit
943 F.3d 1071 (2021)

Facts

Monette Saccameno (plaintiff) entered Chapter 13 bankruptcy. Under the resulting plan, Saccameno paid off a mortgage held by Ocwen Loan Servicing, LLC (Ocwen) (defendant). Ocwen provided Saccameno with statements confirming the payoff, and the debt was discharged by order of the bankruptcy court. However, Ocwen continued demanding money from Saccameno for several years, never providing a reason. Eventually, Saccameno brought suit against Ocwen and its trustee, U.S. Bank National Association (defendant), in federal district court. The jury awarded Saccameno $500,000 in compensatory damages on three claims and an additional $82,000 in compensatory damages—plus $3 million in punitive damages—on a claim brought under the Illinois Consumer Fraud and Deceptive Business Practices Act (ICFA). Ocwen appealed, arguing that the punitive-damages award was unconstitutionally excessive.

Rule of Law

Issue

Holding and Reasoning (St. Eve, J.)

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