Widow filed application to enforce arbitration award of death benefits under Section 19(g) of Workers' Compensation Act. As employer's obligation to widow was payable in installments, each of its deficient payments constituted a new cause of action with its own independent statute of limitations. Thus, court properly applied statute of limitations to bar only those claims relating to deficient payments occurring prior to date which was 5 years prior to date widow filed her application to enforce award. If anything is properly due under final award at time application for judgment is made, trial court should enter judgment as provided in Section 19(g) of the Act. As employer did not move to correct computation of award nor petition for its review, it may not now contest its validity in context of Section 19(g) proceeding.(KNECHT and HOLDER WHITE, concurring.)
Illinois Appellate Court
Civil Court
Workers’ Compensation Act