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Detective’s Claim for Benefits Under the Illinois Workers’ Compensation Act Barred Under the Doctrine of Collateral Estoppel in City of Zion v. Illinois Workers’ Compensation Commission
Workers’ Compensation attorneys don’t often need to dust off their law books to read about Collateral Estoppel, generally stashing the doctrine amongst the vast heap of foggy bar exam memories. But, just like a rare bird emerging from the foothills of the Amazon rainforest, Collateral Estoppel has emerged to inspire hope amongst municipal employers in Illinois. The fresh-off-the-press decision in City of Zion Police Department v. Illinois Workers’ Compensation Commission, 2025 Ill. App. 2d 240758WC-U, discusses the interplay between the Illinois Pension Code and the Illinois Workers’ Compensation Act. Pursuant to the Appellate Court’s decision, a claimant is disallowed from relitigating a causation issue under the Act where the pension board denied a line-of-duty pension.
The claimant in City of Zion, a Detective, sought benefits under the Illinois Workers’ Compensation Act for bilateral wrist injuries he sustained while performing one too many burpees during a firearms training event. Respondent filed a Motion to Dismiss, arguing that the claimant was barred from relitigating causation under the Act since the pension board determined that the claimant’s injuries were not performed in an act of duty. The claimant was awarded a non-duty pension and did not appeal the pension board’s June 18, 2018 decision.
Over at the Illinois Workers’ Compensation Commission, the Arbitrator awarded the claimant benefits, concluding that the issues litigated before the pension board differed from the issues litigated under the Illinois Workers’ Compensation Act. Aside from one ancillary issue regarding medical expenses, the Commission affirmed and adopted the decision of the Arbitrator, and respondent appealed the decision. The Circuit Court reversed the decision of the Commission, concluding that the claimant was bound by the pension board’s decision, and that the pension board already concluded that the injuries were not caused by the training activities in question. The claimant then appealed.
Collateral Estoppel precludes a party from relitigating an issue of fact or law that has already been decided in a prior case between the same parties. The Court examined the standards for receiving a duty disability award under the Pension Code and compared those standards with the requisites for causation under the Illinois Workers’ Compensation Act. According to the Appellate Court in City of Zion, there was no difference between the issue adjudicated before the board and the issue of causation under the Act, “Because claimant cannot establish the requisite element of causation, his claim for benefits under the Act fails.” The Court determined that all of the requirements of Collateral Estoppel were met.
The Court’s decision is rooted in sound logic: Determining whether an injury occurs within the performance of an “act of duty” appears to be equivalent to the standard for causation under the Illinois Workers’ Compensation Act. On the other hand, the City of Zion decision begs the question of whether a municipal employer’s argument that an injury is not causally related to the injury will ever hold water when an employee is given a duty pension. Additionally, if the pension board determines that an employee is entitled to a duty pension, municipal employers need to consider whether a viable accident dispute under the Illinois Workers’ Compensation Act becomes diluted.
Although a Rule 23 Opinion, the decision in City of Zion has a significant impact on municipal employers whose employees are seeking a second avenue of compensation under the Act when duty pension has been denied. Pursuant to the decision, when a claimant has been awarded a non-duty pension, the issue of causation under the Illinois Workers’ Compensation Act has already been litigated. We support the Court’s conclusion in City of Zion, and hope the decision serves to reduce exposure for municipal employers who face rising costs from the dreaded “career-ending” injuries.