Edmonds v. Illinois Workers’ Compensation Commission

Claimant, a retired 30-year coal miner, filed claim under Workers' Occupational Diseases Act, alleging shortness of breath and exercise intolerance as a result of inhaling coal mine dust. District Director's findings in Department of Labor proceedings under Black Lung Benefits Act is not an "adjudication" for purposes of collateral estoppel. Due to informal nature of initial stage of federal proceeding, constraints on nature of evidence for initial submission of claim, and claimant's lack of incentive to fully and fairly litigate his claim before District Director, collateral estoppel does not apply to bar claim under Act. (McCULLOUGH, HOFFMAN, HOLDRIDGE, and STEWART, concurring.)