Michaels v. Michaels

How later courts describe this case

• two-prong test to establish prima facie case of control: (1) that defendant "actually participated in (i.e., exercised control over) the operation of the corporation in general;’’ (2
• "Culpability and good faith are two sides of the same issue, and ... [t]o require the plaintiff ... to prove culpability would amount to giving both parties the burden of proof on the same issue."
• summary judgment granted on issue of knowledge in securities, “controlling person” liability case
• “Illinois courts have long recognized that punitive damages are appropriate when torts are committed with fraud or actual malice or when the defendant acts willfully or with a wanton disregard for the rights of others”