Illinois court upholds punitive damages against a man who froze an HOA's bank account
Illinois court upholds punitive damages against a man who froze an HOA's bank account
2026-09-10 · Illinois · Courts
What happened. On October 3, 2025 the Illinois Appellate Court, Third District, affirmed summary judgment and a punitive damages award in Board of Directors of the Lakelands Estate Homeowner's Ass'n, Corp. v. Pamnani, 2025 IL App (3d) 240564-U. It is a Rule 23 order and is not precedential.1
What the defendant did
He held himself out as acting board president, seized control of association funds, and sent letters on association letterhead announcing that he had frozen the bank account so the association could not pay its bills.
The court held the punitive award neither excessive nor unconstitutional. The board's cross-appeal seeking a larger award and Rule 137 sanctions was rejected.
The footnote that matters most
The freeze caused the association's insurance premium to go unpaid, and the policy was cancelled.
The board then could not prove that the policy would have covered its fees — so it could not recover them as damages.
Why rogue-director cases are hard, and why this one worked
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