Corn Belt Energy Corp. v. Illinois Workers’ Compensation Comm’n

Illinois Appellate Court
Civil Court
Workers' Compensation
Citation
Case Number: 
2016 IL App (1st) 150311WC
Decision Date: 
Tuesday, June 28, 2016
District: 
1st Dist.
Division/County: 
Bureau Co.
Holding: 
Affirmed in part and reversed in part; remanded.
Justice: 
HARRIS

Claimant, a lineman, filed claim for workers' compensation benefits for back injury. Claimant's chiropractic records show that claimant had a significant preexisting condition involving same area of the body, and involving same modes of treatment. A claimant may obtain compensation under the Workers Compensation Act even when he suffers from a preexisting condition of ill-being; recovery depends on claimant's ability to establish that his work-related accident aggravated or accelerated his preexisting condition. Causation in preexisting injury cases may be established without medical opinion evidence and through circumstantial evidence, i.e., a chain of events. Record contains sufficient evidence to show that claimant's work accident aggravated his preexisting back condition of ill-being. Section 8.1b does not make submission of a PPD impairment report a prerequisite to an award of PPD benefits by the Commission.(HOLDRIDGE, HUDSON, and STEWART, concurring; HOFFMAN, specially concurring in part and dissenting in part.)