Cronin v. Village of Skokie

Illinois Appellate Court
Civil Court
Public Safety Employee Benefits Act
Case Number: 
2019 IL App (1st) 181163
Decision Date: 
Tuesday, May 28, 2019
1st Dist.
Cook Co., 1st Div,

Court awarded Plaintiff, who had worked as a full-time firefighter and EMT for the Village for more than 30 years, lifetime health insurance benefits from the Village under Section 10 of the Public Safety Employee Benefits Act. Because Pension Board awarded Plaintiff a line-of-duty disability pension, Plaintiff met the requirements of Section 10(a) of the Benefits Act--that he suffered a catastrophic injury in the line of duty--as a matter of law. Plaintiff also met the requirements of Section 10(b) of the Act:  the only work-related incident presented as a cause of his injury was his act of holding the stretcher as a heavy cardiac patient was dropped onto it, and he presented uncontradicted evidence that he reasonably believed he was responding to an emergency. Thus, Plaintiff is entitled to benefits under the Act. (GRIFFIN and WALKER, concurring.)