Department of Healthcare & Family Services Ex Rel. Black v. Bartholomew

The trial court of Livingston County ordered $9,216.77 of respondent Frank H. Bartholomew’s workers’ compensation settlement be applied toward child-support arrearage and interest due the Illinois Department of Healthcare and Family Services (Department) under an administrative support order. Frank appeals from the order, arguing workers’ compensation benefits are exempt from judgment by Illinois law, including those for child-support arrearages. We affirm.

I. BACKGROUND

In March 2005, Elizabeth and Frank, who were not married, had a son, Nicholas. Frank signed a voluntary acknowledgment of…