Loyola University of Chicago v. Illinois Workers Compensation Commisssion

Illinois Workers' Compensation Commission approved settlement contract, and neither party sought judicial review; thus, settlement contract constitutes a final award under Workers' Compensation Act. Claimant thereafter filed petition for penalties pursuant to Sections 19(k) and 19(l) of the Act, and for attorney fees under Section 16 of the Act. Commission correctly concluded that Respondent is liable for reimbursement of overpayment of long-term disability payments made to claimant by CIGNA. Commission was authorized to address claimant's petition, and Commission had jurisdiction to interpret settlement contract in conjunction with deciding claimant's petition for penalties and attorney fees. Commission had jurisdiction to construe settlement contract, and to consider claimant's petition for penalties and attorney fees. Commission properly found that claimant failed to prove that Respondent's interpretation of settlement contract was unreasonable or vexatious.(HOLDRIDGE, HOFFMAN, HARRIS, and STEWART, concurring.)