Carter v. The Illinois Workers' Compensation Commission

Illinois Appellate Court
Civil Court
Workers' Compensation
Case Number: 
2014 IL App (5th) 130151WC
Decision Date: 
Monday, June 9, 2014
5th Dist.
Randolph Co.
Claimant, who had worked for 22 years as coal miner, filed claim for coal workers' pneumoconiosis. Medical evidence at hearing indicated that Claimant was diagnosed with COPD caused in part by exposure to coal dust, but was not diagnosed with coal workers' pneumoconiosis. Workers Compensation Commission properly found claim time-barred because it was not filed within 3-year statute of limitations for claims alleging occupational diseases other than coal workers' pneumoconiosis, per Section 6(c) of Workers' Occupational Diseases Act. Five-year statute of limitations applies exclusively to coal workers with that diagnosis, rather than COPD, and thus does not apply to Claimant. No equal protection violation as statutory interpretation does not treat similarly situated individuals differently; the two diseases are different conditions diagnosed through different procedures. (HOFFMAN, HUDSON, HARRIS, and STEWART, concurring.)