J-H Alliance Inc. v. The Illinois Workers’ Compensation Commission

Illinois Appellate Court
Civil Court
Concurrent Employment
Citation
Case Number: 
2026 IL App (1st) 251899WC
Decision Date: 
Friday, July 17, 2026
District: 
1st Dist.
Division/County: 
WC
Holding: 
Affirmed.
Justice: 
CAVANAGH

In a workers’ compensation case, the employer appealed from the commission’s determination that the employee was concurrently employed under the Workers’ Compensation Act at the time of her injury. The appellate court affirmed, finding that at the time of the injury the employee was furloughed by her second employer due to the Covid-19 pandemic and that the employee was unable to later be recalled to her employment due to her workplace injury and that the circumstances of the case sufficiently established that the employee’s employment with the second employer would have played a part in her future earnings but for her injury. (HOLDRIDGE, ROCHFORD, MULLEN, and BARBERIS, concurring)