City of Joliet v. Illinois Workers’ Compensation Commission

Respondent appealed from the decision of the Will county circuit court confirming the decision of the Illinois Workers’ Compensation Commission denying its requests for credits against amounts awarded to the claimant under the Workers’ Compensation Act. The appellate court affirmed, finding that the sum respondent sought to recoup was paid to the claimant pursuant to the make-whole [provision in the collective bargaining agreement that the parties were operating under and, as a result, there was no overpayment nor was there an early payment made toward satisfying a future obligation. (HOLDRIDGE, HOFFMAN, CAVANAGH, and BARBERIS, concurring)