Subway v. Illinois Workers’ Compensation Commission

Claimant filed a petition for adjustment of a claim under the Workers’ Compensation Act seeking benefits for a fatal automobile collision that occurred while the decedent was employed by the appellant. The commission granted the application, the circuit court confirmed that decision, and the employer appealed. The appellate court reversed the judgment of the circuit court, set aside the commission’s decision and remanded to the commission for further proceedings, finding that the commission used the incorrect legal analysis with regard to traveling employees. (HOLDRIDGE, MULLEN, CAVANAGH, and BARBERIS, concurring)