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Illinois appellate judges reverse Judge Barberis' workers' compensation decision for lack of jurisdiction

By Heather Isringhausen Gvillo | Oct 4, 2016


Illinois appellate judges from each district came together and vacated Madison County Circuit Judge John Barberis’ ruling that a woman’s injury did not arise out of her work with the Collinsville Rehabilitation & Healthcare Center.

Justice Thomas Hoffman (First District) delivered the Rule 23 decision on Sept. 27, finding that the Madison County Circuit Court lacked jurisdiction in the matter. The case was remanded back to the Illinois Workers’ Compensation Commission for further proceedings.

Justices William Holdridge (Third District), Donald Hudson (Second District), Thomas Harris (Fourth District) and Bruce Stewart (Fifth District) concurred

Claimant Diane Patterson filed an application for adjustment of claim pursuant to the Workers’ Compensation Act, seeking benefits for injuries she allegedly sustained on Aug. 20, 2013, while working for Collinsville Rehabilitation & Healthcare Center.

Following a hearing, an arbitrator found that Patterson failed to prove her injury was the result of an accident from work. The arbitrator declined to address the remaining issues and denied workers’ compensation benefits.

Patterson sought review of the decision by the Illinois Workers’ Compensation Commission. The Commission reversed the arbitrator’s decision on July 7, 2015, with one commissioner dissenting. The Commission then remanded the matter back to the arbitrator to address the issues “previously deemed moot.”

Collinsville Rehabilitation filed a petition for judicial review in the Madison County Circuit Court.

Barberis reversed the decision of the Commission on Nov. 18, 2015, “holding that the Commission’s determination that the claimant’s accident arose out of and in the course of her employment was against the manifest weight of the evidence.”

Patterson appealed.

Hoffman wrote that while the parties did not raise the issue of the Madison County Circuit Court’s jurisdiction on appeal, “this court has an obligation to examine the jurisdictional issue sua sponte. That obligation stems from the fundamental principle that, if the circuit court lacked subject matter jurisdiction, then its orders are void and of no effect.”

The appellate court stated that only final determinations of the Commission are appealable.

“Accordingly, the decision issued by the Commission was not a final determination because it mandated further administrative proceedings and did not dispose of the claimant’s request for [temporary total disability] benefits …,” the decision states.

“In the absence of a final determination by the Commission, the circuit court lacked the requisite subject matter jurisdiction to entertain this mater and, therefore, its order reversing the Commission’s decision is void,” it continues.

Madison County Circuit Court case number 15-MR-196

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