Joiner v. Illinois Workers’ Compensation Comm’n 

Illinois Appellate Court
Civil Court
Workers' Compensation
Citation
Case Number: 
2017 IL App (1st) 161866WC
Decision Date: 
Friday, September 29, 2017
District: 
1st Dist.
Division/County: 
Cook Co., WC Div.
Holding: 
Affirmed.
Justice: 
HOLDRIDGE

(Court opinion corrected 11/14/17.)Plaintiff filed workers' compensation claim and a common law claim related to the same accident against the employer and a 3rd-party defendant. Parties entered into global settlement agreement in the civil action, which purported to settle both workers' compensation claim and the civil action. Arbitrator approved parties' settlement agreement and ordered Plaintiff to pay attorney fees to the 3 attorneys who had represented him at various times during Commission proceedings. Workers' Compensation Commission has exclusive jurisdiction to resolve disputes as to attorney fees arising out of the representation of a claimant in a workers' compensation case. Court properly dismissed Plaintiff's petition for judicial review for lack of subject-matter jurisdiction, based on Plaintiff's failure to file an appeal bond under Section 19(f)(2) of Workers' Compensation Act. That bond requirement is not limited to employers, and is not limited to only compensation awards. (HOFFMAN, HUDSON, HARRIS, and MOORE, concurring.)