This morning, the Illinois Supreme Court threw out a $1.2 billion damages award and decertified an improperly certified class in the case of Avery v. State Farm (Feb. 20). The decertification of the class and criticism of the vague finding of consumer fraud means that the $10 billion verdict in the improperly certified Madison County consumer fraud class in the Philip Morris case will likely be thrown out, also, and the stock market has responded accordingly. "The most striking deficiency in DeFrank's claim that State Farm violated the Consumer Fraud Act is his lack of actual damage." This is a deficiency common to many Madison County class actions, and is a promising sign for the law and for American consumers. Michael Greve criticized this aspect of the lower court decisions in Avery in his monograph Harm-Less Lawsuits? Other posters are sure to have more details later in the day.