Cole v. Byrd

The issue presented in this matter is whether an insurer is entitled to reimbursement from a plaintiff for payments the insurer made to a consulting firm, purportedly on the plaintiffs behalf. The insurer seeks reimbursement from proceeds the plaintiff recovered from third-party tortfeasors. The circuit court of De Witt County found that the services provided by the consulting firm were case-management services, and the insurer was not entitled to reimbursement under the Workers’ Compensation Act (Act) (820 ILCS 305/1 (West 1992)). The appellate court reversed the circuit court, finding that…