Ravenswood Disposal Services v. Illinois Workers’ Compensation Comm’n

Illinois Appellate Court
Civil Court
Worker's Compensation Act
Case Number: 
2019 IL App (1st) 181449WC
Decision Date: 
Friday, June 28, 2019
1st Dist.
Cook Co., WC Div.

Employee was, while working, pinned between 2 vehicles resulting in his death. Employee's minor son qualifies as a dependent under Section 7(a) of the Workers' Compensation Act, event though he was adopted by his stepfather after his father's death. The Act contains no express language terminating minor's right to benefits by reason of his adoption where he otherwise qualified for benefits based on his age at time of accident. Ample evidence supported Commission's determination that minor was dependent on his father at the time of the accident. Employer lacked a reasonable basis for challenging existence of an employment relations, and decedent's status as an employee gave rise to employer's obligation to pay his medical expenses.  Thus, it was not irrational for Commission to impose penalties and late fee on employer for failure to pay decedent's medical expenses.(HOLDRIDGE, HUDSON, CAVANAGH, and BARBERIS, concurring.)