The second COVID-19 presumption case has been decided! On November 3, 2021, Arbitrator Cantrell issued a decision in the case of Tonia Dalton v. Saline Care Nursing and Rehabilitation Center (21 WC 008010), once again addressing Illinois’ COVID-19 presumption.

On April 13, 2020, the Illinois Workers’ Compensation Commission created an emergency amendment to Rule 9030.70, expanding the Commission’s Rules of Evidence to include a rebuttable presumption for first responders and front-line workers exposed to COVID-19.