Gruszeczka v. IL Workers' Comp. Comm'nAnnotate this Case
The employee alleged that, while at work in 2004, he was involved in an accident that resulted in a condition for which he sought compensation. A Workers’ Compensation Commission arbitrator denied benefits, citing lack of causation, and, in 2009, the Commission adopted the decision. The trial court confirmed the denial. The appellate court vacated, finding that the lower court lacked subject matter jurisdiction. The employee had calculated the 20-day time period for filing, Workers’ Compensation Act, section 19(f)(1), using the date on which required documents were mailed to the court, rather than the date on which the documents were received and file-stamped. The Illinois Supreme Court reversed and remanded, finding that the so-called “mailbox rule,” which has applied to notices of appeal from the trial to the appellate court and to petitions for the Workers’ Compensation Commission’s review of arbitrators’ decisions, also applies to commencement of an action for judicial review of a Commission decision, which is an exercise of special statutory jurisdiction. Notice to the other party and the statute of limitations were not factors in this case and, absent a clear directive from the legislature, allowing the mailbox rule in such a case is most consistent with Illinois law.
Alliance Contractors of McHenry County was the employer of the claimant here. He alleged that, while working in 2004 on a job for the employer in Sycamore, in De Kalb County, he had been involved in an accident that resulted in the condition of ill-being which is the subject of this claim. However, an arbitrator for the Workers’ Compensation Commission denied benefits, finding a lack of causation, and the Commission adopted that decision in 2009.
Gruszeczka sought judicial review of the Commission’s decision in the circuit court of De Kalb County, which transferred venue to the circuit court of McHenry County. The latter court ruled on the merits and confirmed the denial of benefits. Gruszeczka then sought appellate review. The appellate court, however, found that the circuit court had never had subject matter jurisdiction. The circuit court judgment was vacated and the appeal was dismissed.
In the employee’s appeal from the appellate court to the Illinois Supreme Court, he claimed that his action for circuit court review had been presented within the 20-day time period required by section 19(f)(1) of the Workers’ Compensation Act. However, he computed this 20-day period using the date the required documents were mailed to the clerk of the circuit court, rather than from the date on which the documents were received and file-stamped by the clerk. This so-called “mailbox rule” has in the past been held to apply to notices of appeal from the circuit to the appellate court and to petitions for the Workers’ Compensation Commission’s review of arbitrators’ decisions. The question presented here was whether the mailbox rule applies to the commencement in circuit court of an action for judicial review of a Commission decision, which is an exercise of special statutory jurisdiction. However, the applicable statute does not provide clarification.
The mailbox rule does not apply to the commencement of a new civil action in the circuit court, but the Illinois Supreme Court noted that, in that example, what is at issue is notice to the other party and the statute of limitations. Those factors are not present here.
The supreme court said that the legislature is obviously aware that, for decades, courts have been construing statutes that contain no mailbox rule as containing one. The legislature has stepped in to preclude the mailbox rule only as to the Election Code. It is quite possible that the legislature is comfortable with the widespread adoption of the mailbox rule by the courts and sees no need to specifically provide for it in every statute. If that is not the case, the legislature needs to clearly set this forth in the statute. Absent such a clear directive from the legislature, allowing the mailbox rule in an appeal from the Commission to the circuit court is the result most consistent with Illinois law.
The appellate court’s judgment was reversed and the cause was remanded there for that court’s consideration of other issues.