Baumgardner v. Illinois Workers' Compensation Commission

JUSTICE STEWART,

specially concurring:

I concur in the majority decision in this case. Respectfully, I write separately, however, to explain my reasons for concurring and to reconcile my concurrence in this case with my partial dissent in City of Chicago v. Illinois Workers’ Compensation Comm’n, 409 Ill. App. 3d 258 (2011).

In City of Chicago, the majority, applying a de novo standard of review, held that the claimant, who asserted separate claims for two back injuries at a consolidated hearing, could only obtain one recovery for permanent partial disability (PPD) under section 8(d) of the Act.…