In Lawlor v. North American Corporation (lower court opinion reported at FEB hyperlink), the Illinois Supreme Court ruled that the employer was liable for the actions of its outside investigator who engaged in "pretexting" to obtain a former employee's personal cell phone records. Lawlor, a salesperson, left North American to work for a competitor. Concerned that she was committing unfair competition, the company retained an outside investigator to investigate her activities. Although North American did not specifically ask for her personal cell phone phone records, the vendor provided those records to North American, and North American reviewed them for calls to North American customers after her termination. Upon learning that North American had accessed her personal telephone records, Lawlor successfully sued for invasion of privacy, and obtained a jury award against North American of $65,000 in compensatory damages, and $1.75 million in punitive damages. The court affirmed the compensatory damages award concluding that the jury could reasonably infer that North American knew that its vendor unlawfully obtained Lawlor's private cell phone records. However, the court reduced the punitive damages award to $65,000, as there was no evidence that North American engaged in an intentional, premeditated scheme to harm Lawlor.