Eddards v. Illinois Workers’ Compensation Comm’n

Claimant sought workers' compensation benefits for injury to her right shoulder. Arbitrator awarded TTD, PPD, and medical expenses. Respondent filed timely motion to recall arbitrator's decision to correct a clerical error. Arbitrator issued a corrected decision. Workers' Compensation Commission reversed arbitrator's decision, finding that claimant failed to prove that her injury arose out of and in course of her employment. Circuit court confirmed Commission's decision. Respondent employer failed to properly perfect review of arbitrator's decision by seeking review of arbitrator's original decision rather than the corrected decision. Because Commission issued a corrected decision, the original decision was not a final, appealable decision. Respondent employer never filed a petition requesting review of arbitrator's corrected decision within the statutorily-required period. (HOLDRIDGE, HOFFMAN, HARRIS, and MOORE, concurring.)