Narrative Opinion Summary
The appellate court, presided over by Justice Woodward, evaluated an appeal from National Lock Hardware regarding a lower court's decision that awarded interest to an employee, Anna A. Childs, on her Workers' Compensation Act award. The primary legal issue revolved around the accrual of interest from the date of the arbitrator's award, as contested by Childs, who cross-appealed for interest to accrue from the arbitrator's award rather than the Industrial Commission's modified decision. Initially, Childs received an award for temporary total and permanent partial disability, as well as medical expenses, which the employer appealed. The Industrial Commission subsequently reduced the temporary total disability award, and this decision was upheld by both the circuit and appellate courts. Childs further sought interest post the Industrial Commission's modification, but the circuit court's decision to award interest was reversed by the appellate court. The appellate court concluded that under section 19(n) of the Workers' Compensation Act, interest should not accrue from the arbitrator's award date if the award is modified by a reduction. Consequently, the appellate court reversed the circuit court's decision on interest, denying Childs additional interest and attorney fees.
Legal Issues Addressed
Application of Section 19(n) of the Workers' Compensation Actsubscribe to see similar legal issues
Application: In this case, the court applied section 19(n) to determine that interest should not accrue from the arbitrator's award date because the award was decreased by the Industrial Commission.
Reasoning: The court noted that since the arbitrator’s award was made before July 1, 1984, prior provisions of section 19(n) of the Act applied, which stipulates that interest should accrue from the date of the arbitrator's award only if the Industrial Commission confirmed or increased it.
Interest on Workers' Compensation Awardssubscribe to see similar legal issues
Application: The appellate court determined that interest on a workers' compensation award should not accrue from the date of the arbitrator's award if the Industrial Commission modifies the award by reducing it.
Reasoning: The court noted that since the arbitrator’s award was made before July 1, 1984, prior provisions of section 19(n) of the Act applied, which stipulates that interest should accrue from the date of the arbitrator's award only if the Industrial Commission confirmed or increased it. The Commission's modification decreased the award, thus indicating that section 19(n) did not apply.