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355 Ill. App. 3d 708

823 N.E.2d 1103

291 Ill.Dec. 517

Armour Swift-Eckrich v. INDUSTRIAL COM'N

Appellate Court of Illinois

Decided February 2, 2005

Appellate Court of Illinois · decided 2005-02-02

Good law ✅— No negative treatment on recordhow we know

Decided 2005-02-02

How this case has been cited

Cited by 5 later decisions — most recently December 2020

4 state decisions

20200520102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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JUSTICE GOLDENHERSH,

¶1dissenting:

¶2I respectfully dissent. I disagree with the majority on two basic elements of its disposition. First, the majority note that section 19(k) penalties may be awarded in cases of unreasonable or vexatious delay of payment. Their disposition, however, deals glancingly with the question of unreasonableness and concentrates essentially on vexatiousness or the lack of vexatiousness. The crux of the issue met by the parties in this appeal is the question of unreasonableness, not vexatiousness.

¶3Relying on McMahan, the majority limit the application of section 19(k) to situations where there has been vexatious conduct on the part of the employer. McMahan does not apply to the case at hand. McMahan addressed issuing penalties for delay in continuing weekly compensation benefits due an employee during the period of temporary total disability (TTD). McMahan, 183 Ill. 2d at 514-15, 702 N.E.2d at 552-53. McMahan limited section 19(k) to cases of vexatious conduct in those situations in order to distinguish section 19(k) from section 19(1), which also allows for penalties for not making continuing payments for TTD. McMahan, 183 Ill. 2d at 514-15, 702 N.E.2d at 552-53. Extending McMahan to cases involving delay after the entry of an award ignores the plain language of section 19(k).

¶4As to the real issue at hand, the reasonableness or unreasonableness of employer’s conduct, the circuit judge, Judge Colwell, who reversed the initial Commission decision, rendered these words of wisdom in his order:

“The sole excuse in justification of the delay, offered by the [employer], seems to be an unexplained change in personnel.
It is unreasonable that the [claimant] should be required to undertake the burden of the consequences of [the employer’s] personnel practices or of its work place policies.”

¶5Judge Colwell was right. Accordingly, I would affirm the circuit court of Kane County.

¶6HOLDRIDGE, J., joins this dissent.

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