This Comment explores the fraudulent scheme or device exception to the general rule in Illinois prohibiting a tort action for promissory fraud. The Comment advocates the adoption in Illinois of the "total facts test" set out in Zaborowski v. Hoffman Rosner Corp. which would allow for recovery of punative damages, but only when the "scheme" consists of more than a single misrepresentation.
College of Law
Northern Illinois University Law Review
Nolasco, Raymond R.
"Promissory Fraud in Illinois: What is a Scheme to Defraud?,"
Northern Illinois University Law Review: Vol. 8:
2, Article 5.
Raymond R. Nolasco, Comment, Promissory Fraud in Illinois: What is a Scheme to Defraud?, 8 N. Ill. U. L. Rev. 485 (1988).