The Fifth District Court on Tuesday affirmed in part and reversed in a part a Madison County ruling over a former Granite City firefighter’s benefits.
In an opinion delivered by Justice James Wexstten, the appellate court affirmed Associate Judge Clarence Harrison’s determination that James Pyle was “catastrophically injured” and that the city should have paid his health insurance premiums until he became eligible for Medicare in 2008.
The appeals panel, however, reversed the portion of Harrison’s ruling that required the city to pay Pyle’s premiums to supplement his Medicare coverage for life and remanded the matter for further proceedings.
The case over benefits stems from injuries Pyle sustained as a Granite City firefighter, a job he had from 1977 to 2000.
He hurt his right shoulder and lower back while moving a water hose at two separate residential fires in 1998 and 1999. He was treated with physical therapy and epidural injections before having surgery.
Pyle ultimately sought a line-of-duty disability pension, claiming that his injuries prevented him from returning to work.
The city’s pension board in 2000 awarded Pyle a disability pension.
Four years later, he sued the city and six city officials, seeking lifetime benefits and reimbursement of the past premium payments, as well as litigation expenses and attorney fees.
He moved for summary judgment in 2011, claiming that the city improperly denied him payment for the premiums owed under the Public Safety Employee Benefits Act (PSEBA).
The PSEBA requires an employer to pay the entire premium of an employer’s health insurance plan if he or she suffers a “catastrophic injury” in the line of duty. It also provides lifetime benefits for firefighters who were injured while responding to an emergency.
In 2011, Harrison granted Pyle’s motion for summary judgment and found he was eligible for the requested benefits under PSEBA. He awarded Pyle $22,440 for past premiums he paid and ordered the city to pay $350 as premiums to supplement his Medicare coverage.
On appeal, the city claimed that Harrison was wrong when he determined Pyle was “catastrophically injured” and entitled to lifetime benefits under the PSEBA.
The city argued that the definition of “catastrophic injury” that the Supreme Court coined in 2003 in Krohe v. City of Bloomington “should be revised for public policy reasons and to bring the definition of ‘catastphroic’ in accord with common understanding and legislative intent,” according to the appellate court opinion
The city claimed that such a definition could encourage people to seek line of duty disability benefits rather than trying to go back to work, something that would have a substantial financial impact on municipalities.
“The City’s arguments overlook the fact that we are required to follow the decisions of the Illinois Supreme Court,” Wexstten wrote.”[W]e cannot overturn or modify the Supreme Court’s decision in Krohe.”
The appeals panel determined that while Harrison was right when he found Pyle qualified for a line of duty disability pension under the PSEBA, he was wrong to require the city to do so after Pyle became Medicare eligible.
“If the city had been paying premiums for Pyle and his spouse, and only Pyle had become Medicare eligible, the benefits payable under … the PSEBA would have reduced only by the amount due for Pyle’s premium,” Wexstten wrote.
“The city would have continued to pay health insurance premiums for his spouse under the section’s conditions,” he explained. “However, because the city here paid premiums solely for Pyle, Pyle’s benefits were reduced in their entirety when he became eligible for Medicare benefits.”
Wexstten wrote that when Pyle became eligible for Medicare, the benefits provided in the city’s insurance plan supplemented his Medicare coverage and gave him the option to pay for city-approved supplemental benefits.
This, the appellate court held, put Pyle “in the position he would have been in had he not been injured.”
“The plain language of the PSEBA and the Illinois Insurance Code does not support the conclusion that the city is obligated to pay premiums for Pyle’s supplemental Medicare coverage,” Wexstten wrote.
Justices James Donovan and Richard Goldenhersh concurred with Wexstten.
Jane Unsell and Erin M. Phillips of Unsell & Schattnik in Wood River represented the defendants.
Arlington Heights attorney Thomas W. Duda represented Pyle.