The Northern District of Illinois dismissed a suit last month brought against a former member of the US House of Representatives alleging that the representative was liable to his campaign donors under fraud, promissory estoppel, and unjust enrichment theories.
The suit alleged the former representative had promised his donors he would be an "honest politician" to attract campaign donations, which he then illegally spent for personal purposes. The court dismissed the donor's suit, stating that when a politician refers to himself as "honest" and "different [from other corrupt politicians]," his statement amounts to nothing more than "inactionable puffery."
The court further ruled that the donor's claim that he would not have donated to the politician had he known of the politician's dishonesty must fail because the donor could not show the representative had any legal duty to disclose information to his donors that contradicted his campaign promises of honesty.
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