Angela Gambino, individually and as Agent for Brokerage Resources, Inc. of Illinois v. Pauline A. Petitt and Brokerage Resources, Inc. of Missouri

District Court, N.D. Illinois·Decided July 28, 2026·No. 1:25-cv-08216·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

) ANGELA GAMBINO, individually ) and as Agent for BROKERAGE ) RESOURCES, INC. of Illinois, ) ) Plaintiff, ) Case No. 25-cv-08216 ) v. ) ) Judge Sharon Johnson Coleman PAULINE A. PETITT and ) BROKERAGE RESOURCES, INC. ) of Missouri, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Angela Gambino, individually and as Agent for Brokerage Resources, Inc. of Illinois (“BRI”) (“Plaintiff”) brings claims against Pauline A. Petitt and Brokerage Resources, Inc. of Missouri (“BRM” and, together with Petitt, “Defendants”) alleging breach of contract, fraud, and unjust enrichment related to withholding commission payments from Plaintiff’s insurance sales. Before the Court is Defendants’ motion to dismiss. For the following reasons, the Court grants in part and denies in part Defendants’ motion to dismiss [20]. BACKGROUND The following facts are drawn from Plaintiff’s complaint and accepted as true for the purpose of resolving Defendants’ motion. Gambino is an Illinois insurance producer and the sole owner and principal of BRI. Plaintiff alleges that she and Defendants had a “longstanding and consistently followed compensation agreement” since 2014, wherein Plaintiff was entitled to receive 90% of the first-year commissions and renewal commissions from insurance policies she sold. Defendants, not Plaintiff, were often listed as the agent of record in the documentation for Plaintiffs’ insurance sales. Defendants received the commission checks from insurers and would remit Plaintiff her 90% share of the commission payments. Plaintiff alleges that on July 3, 2017 she and Defendants entered into a written agent agreement (the “2017 Agreement”) with BRM memorializing their course of business. Relying on this arrangement, she “personally solicited, prepared, and submitted every policy application related to the commissions at issue, often using her own insurance platform credentials.” Defendants honored their

agreement to remit 90% of the commission to Plaintiff until January 2018, when Plaintiff claims that Defendants “abruptly stopped” the payments. Defendants sent Plaintiff a letter purporting to be a “full release of all insurance companies she is licensed with through [BRM], effective immediately.” Plaintiff accuses Defendants of failing to pay her the commissions she earned “despite her repeated demands.” As a result of Defendants’ alleged breach of their agreement, Plaintiff claims approximately $144,000 in damages from withheld commission payments. LEGAL STANDARD A motion to dismiss pursuant to Rule 12(b)(6) for failure to state a claim tests the sufficiency of the complaint, not its merits. See Camasta v. Jos. A. Bank Clothiers, Inc., 761 F.3d 732, 736 (7th Cir. 2014). Therefore, when considering such a motion, the Court accepts well pleaded factual allegations as true and draws all reasonable inferences in favor of the plaintiff. Erickson v. Pardus, 551 U.S. 89, 94, 127 S. Ct. 2197, 167 L. Ed. 2d 1081 (2007) (per curiam); Trujillo v. Rockledge Furniture LLC, 926 F.3d

395, 397 (7th Cir. 2019). To survive a motion to dismiss, plaintiff must “state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007). A complaint is facially plausible when the plaintiff alleges “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L.Ed.2d 868 (2009). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. at 678 (citing Twombly, 550 U.S. at 555, 127 S.Ct. 1955). DISCUSSION Defendants move to dismiss Plaintiff’s complaint on a myriad of grounds. As to Count I (Breach of Contract) they claim that Plaintiff alleges an unenforceable contract; that Plaintiff’s claims are barred by the doctrine of in pari delicto; that Plaintiff has not alleged mutual assent; and that

Plaintiff’s breach of contract claims are time-barred. As to Counts II (Common Law Fraud), Defendants argue that any fraud claim is barred by the economic loss doctrine; that Plaintiff alleges nonactionable promissory fraud; that Plaintiff fails to plead the elements of fraud with particularity; and that Plaintiff could not have justifiably relied on the alleged misrepresentations. Finally, as to Count III (Unjust Enrichment) Defendants argue that the claim is precluded by the express contract that Plaintiff alleges. Defendants also argue that no basis exists for imposing individual liability against Petitt at all. I. Breach of Contract a. Unenforceability & In Pari Delicto Defendants argue that Plaintiff’s complaint must be dismissed because in bringing her case she “admits to participating in a scheme to receive commissions for which she was legally ineligible.” Specifically, Defendants claim that an agreement to pay Plaintiff commissions “violates the direct

statutory prohibition on producer compensation” found in the Illinois law. The Illinois Insurance Code provides that an insurer may not pay a commission to a person for selling insurance “if that person is required to be licensed under this Article and is not so licensed at the time of selling … the insurance.” 215 ILCS 5/500-80(a). Defendants assert that the phrase “not so licensed” means that one must be both properly licensed and “authorized for the specific conduct at issue,” i.e., “selling insurance on behalf of a particular insurer.” According to Defendants, the required authority to sell insurance “on behalf of a particular insurer” is established through a formal “appointment.” Defendants argue that the fact that Plaintiff admits that she was not always listed as the “agent of record” means that she was not “appointed” to sell insurance on behalf of Defendants, therefore lacking the specific authorization required to be “licensed” and qualify for commission payments. Defendants fail to explain how Plaintiff’s licensure was insufficient and how she was unauthorized to sell on behalf of Defendants, so as to render her ineligible to collect commission

payments. Defendants characterize an “appointment” as a “a legally significant status whose termination is regulated in part under [215 ILCS 5/500-85].” That provision says nothing to require a formal “appointment” for authorization to sell insurance on behalf of an insurer. It sets out notice requirements for when an insurer terminates the “appointment, employment, contract, or other insurance business relationship” with a producer, plainly contemplating methods of authorization other than “appointment.” For the same reason, Defendants’ argument that Plaintiff’s claims are barred by the doctrine of in pari delicto also fails. Defendants argue that Plaintiff was in pari delicto—or “in equal fault”—because she claims to be “the direct beneficiary of the illegal arrangement she now seeks to enforce.” But because Defendants have not shown that the alleged contract was illegal, they have not shown a basis to dismiss Plaintiff’s claim as “in equal fault.” b. Mutual Assent & Statute of Limitations Next, Defendants claim that there was “no meeting of the minds on the specific contract

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Angela Gambino, individually and as Agent for Brokerage Resources, Inc. of Illinois v. Pauline A. Petitt and Brokerage Resources, Inc. of Missouri, (N.D. Ill. 2026).

Angela Gambino, individually and as Agent for Brokerage Resources, Inc. of Illinois v. Pauline A. Petitt and Brokerage Resources, Inc. of Missouri (Angela Gambino, individually and as Agent for Brokerage Resources, Inc. of Illinois v. Pauline A. Petitt and Brokerage Resources, Inc. of Missouri) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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