Gruszeczka v. IL Workers’ Comp. Comm’n

The employee alleged that, while at work in 2004, he was involved in an accident that resulted in a condition for which he sought compensation. A Workers’ Compensation Commission arbitrator denied benefits, citing lack of causation, and, in 2009, the Commission adopted the decision. The trial court confirmed the denial. The appellate court vacated, finding that the lower court lacked subject matter jurisdiction. The employee had calculated the 20-day time period for filing, Workers’ Compensation Act, section 19(f)(1), using the date on which required documents were mailed to the court, rather than the date on which the documents were received and file-stamped. The Illinois Supreme Court reversed and remanded, finding that the so-called “mailbox rule,” which has applied to notices of appeal from the trial to the appellate court and to petitions for the Workers’ Compensation Commission’s review of arbitrators’ decisions, also applies to commencement of an action for judicial review of a Commission decision, which is an exercise of special statutory jurisdiction. Notice to the other party and the statute of limitations were not factors in this case and, absent a clear directive from the legislature, allowing the mailbox rule in such a case is most consistent with Illinois law. View "Gruszeczka v. IL Workers' Comp. Comm'n" on Justia Law