Curtis v. Illinois Workers' Compensation Commission

Illinois Appellate Court
Civil Court
Citation
Case Number: 
2013 IL App (1st) 120976WC
Decision Date: 
March 11, 2013
District: 
1st Dist.
Division/County: 
Cook Co., WC Div.
Justice: 
HUDSON
Holding: 
Affirmed.
(Court opinion corrected 3/26/13.) Claimant, a police officer/paramedic, alleged accidental hand injury sustained when he tripped and fell while chasing a suspect. Under Workers Compensation Act, although permanent injuries can "increase" or "diminish", only temporary disabilities can "recur". Only TTD payments may thus be "re-established".Thus, scope of 19(h) of Act is not limited to permanency benefits, but also covers TTD benefits. (HOLDRIDGE, HOFFMAN, HARRIS, and STEWART, concurring.)