Does Punitive Damages Claim Survive the Dissolution of the Assignor Corporation ?

In Grunloh v. Effingham Equity, Inc., 174 Ill. App. 3d 508, 519, 528 N.E.2d 1031, 124 Ill. Dec. 140 (1988), the Fourth District considered whether a punitive damages claim was assignable by a corporation and would survive the dissolution of the assignor corporation. Grunloh, 174 Ill. App. 3d at 510. Finding no authority that had considered whether punitive damages actions were assignable, the court looked to precedent addressing the survival of punitive damages claims. Grunloh, 174 Ill. App. 3d at 518-19. Citing Raisl v. Elwood Industries, Inc., 134 Ill. App. 3d 170, 479 N.E.2d 1106, 89 Ill. Dec. 100 (1985), the court stated that the aforementioned three factors are "relevant" in considering whether strong equitable considerations favor survival of punitive damages claims. Grunloh, 174 Ill. App. 3d at 519.