Mulligan v. Illinois Workers' Compensation Commission

Presiding Justice McCullough and Justices Hudson and Hoffman concurred in the judgment and opinion.

Justice Holdridge specially concurred, with opinion.

OPINION

The central issue in this appeal concerns the requirement in section 12 of the Illinois Workers’ Compensation Act (820 ILCS 305/12 (West 2008)) (the Act) that the proponent of medical testimony furnish a report of the medical expert to the other party at least “48 hours before the time the case is set for hearing.” This appeal is brought by the claimant, William Mulligan, from an order of the circuit court which confirmed a decision of…