Richard P. Vancura, Appellee v. Peter Katris (kinko’s Inc., Appellant)

Summary

The Illinois Supreme Court held that the Illinois Notary Public Act limits an employer’s common-law liability for negligent supervision of a notary by requiring proof that the employer had some knowledge of the notary’s misconduct. It further held that an employer that voluntarily provides notary training has a duty to ensure that the training conforms to the Act, but Kinko’s satisfied that duty on the evidence presented. The court therefore reversed the liability judgment against Kinko’s and remanded for entry of judgment in its favor on both counts.