63 Ill. 553 (1872)
After a trial for trespass, Defendant spit in Plaintiff’s face. Plaintiff sued Defendant for battery and the trial court rendered a judgment of $1,000 for Plaintiff. Defendant appealed the judgment on the grounds that the judgment was excessive.
The issue presented to the court of appeal was whether punitive damages can be awarded in a case of battery. The court ruled in the affirmative.
The court reasoned that an award of punitive damages can discourage people from committing acts such as those committed by Defendant and, therefore, such damages are recoverable in a case of battery.