Vancura v. Katris

After a bench trial, the circuit court found defendant Kinko’s, Inc. (Kinko’s), liable for damages resulting from its employee’s notarization of a forged signature on a mortgage assignment. Kinko’s1 seeks reversal, contending the court misconstrued section 7 — 102 of the Illinois Notary Public Act (5 ILCS 312/7 — 102 (West 1996)) (Act) regarding employer liability and further erred by imposing liability under the common law for negligent training and supervision. This is a case of first impression regarding an employer’s liability under the Act for a notary’s “official misconduct.” 5 ILCS…