University of Illinois Hospital v. Illinois Workers’ Compensation Commission

As two commissioners who found that claimant was entitled to receive benefits did not agree as to a permanency award, a majority of the commissioners did not approve the PPD award, and the Commission's decision was not final as it did not dispose of claimant's request for permanent disability benefits per Section 19(e). In absence of a final determination by the Industrial Commission, the circuit court lacked requisite subject-matter jurisdiction to enter order confirming Commission's decision. (HUDSON, HOLDRIDGE, APPLETON, and STEWART, concurring.)