Illinois Appellate Court
Civil Court
Workers' Compensation
In Section 19(f)(1) of Workers' Compensation Act, which provides that proceeding for judicial review of Commission decision shall be commenced within 20 days of receipt of notice or decision, commencement date is date upon which proceeding for judicial review is received by clerk of court, not date that document was mailed to clerk. Section 19(f) of Act does not contain a mailbox rule. (McCULLOUGH and HUDSON, concurring; STEWART and HOLDRIDGE, dissenting.)