Alcorn v. Mitchell – Case Brief
Alcorn v. Mitchell, 63 Ill. 553 (Ill. 1872).
Facts: Alcorn (D) spit in Mitchell’s (P) face after a trial for trespass. Mitchell sued Alcorn for battery and was awarded a judgment of $1,000. D appealed on the grounds that the damages were excessive.
Issue: Can the court award punitive damages for battery?
Holding and Rule: Yes. The court has the authority to award punitive damages if it is necessary to avoid physical retaliation for highly offensive conduct. The court reasoned that it is better to bring these matters to the court rather than allow people to settle them physically. Offering monetary compensation discourages these offensive acts from reoccurring.
Disposition: Affirmed for P.