In October of this year I wrote a blog post about Armstead v. Nat’l Freight, Inc., a civil dispute before the Illinois Supreme Court that concerned the potential impact of a Worker’s Compensation settlement contract on a civil negligence case. The Supreme Court issued its decision earlier this month in Armstead v. Nat’l Freight, Inc., 2021 IL 126730, although it probably wasn’t exactly what the parties were expecting.
To summarize the original claims, Clifton Armstead was employed as a semi-truck driver for Manfredi Mushroom Company in Pennsylvania. He was driving through Illinois when he was struck by a semi-truck driver of National Freight, Inc. and suffered injuries to his back, shoulder, and knee. Armstead filed suit against the other driver and National Freight for Negligence in Illinois, shortly after filing a Worker’s Compensation claim in Pennsylvania with his employer Manfredi Mushroom Company. He then settled that Worker’s Compensation claim, and signed a settlement agreement that stated that stated that the “precise nature” of his injury was a “right knee strain.” National Freight then filed a motion purporting to be a “Motion for Partial Summary Judgment or Summary Determination of a Major Issue” requesting that the Illinois court limit the claims of the damages to the knee strain, since they argued that Armstead had effectively admitted that the knee strain was his only injury.
The Circuit Court agreed with National Freight, and held that the Worker’s Compensation Settlement prevented Armstead from claiming other injuries. Armstead appealed this decision, but during the process of appeal he also voluntarily dismissed the case against National Freight and the other driver, with leave to refile. It’s not clear in the decision why this decision was made; it’s possible that, if the case was only about the knee strain, Armstead felt that the process of litigation was simply not worthwhile.
The Appellate Court agreed with the lower court and upheld the decision, saying that as a matter of evidence the Plaintiff was estopped from relitigating something which was settled through the Worker’s Compensation process in Pennsylvania. Armstead appealed again, but the Illinois Supreme Court had a very different take on the matter.
Rather than making a decision on the effect of the Pennsylvania Worker’s Compensation Settlement Agreement on the civil case in Illinois, the Court ruled that there never should have been an appeal granted in the first place. By the constitution of Illinois, not every decision of a court is appealable—only those which are “final judgements”. Ill. Const. 1970, art VI, § 6. Now, “final judgement” doesn’t have to be something that totally resolves the case (for example, if only one of several Defendants is dismissed from a case that can generally be appealed right away), but it does actually have to actually dispose of a “definite and separate” part of the case. Blumenthal v. Brewer, 2016 IL 118781, ¶ 25 (2016).
The Supreme Court found that limiting Armstead’s damages to just the knee strain was not a “definite and separate” part of the case. At best, the decision of the Circuit Court disposed of one of the ancillary issues in the claims, not a separate claim itself. This nub of the damages in the negligence claims is not appealable itself. Thus, the Supreme Court vacated (or erased) the ruling of the Appellate Court, since it never should have had the case in the first place. Effectively, the original ruling of the Circuit Court thus stood as the final say on the matter of what injury Armstead could claim.
This is all a bit of a shame, because the question was an important one: the legal implications of settlement contracts, especially in the overlap between Worker’s Compensation and Civil claims, is important. It’s more problematic for Armstead, however, since he had already dismissed the rest of the case and the Supreme Court’s decision, failing to revive the rest of the claim, therefore just ends his case completely. Again, this might have been a calculated decision that the knee strain wasn’t worth pursuing on it’s own, but the whole thing is a bit of an unfortunate end to an interesting case.
Attorney Travis Dunn