1. WCLA MCLE
City of Chicago & Baumgardner: Multiple Permanency Awards
Wednesday May 18, 2011 from 12:00 pm to 1:00 pm
James R. Thompson Center Auditorium, Chicago, IL
1 Hour General MCLE Credit

2. City of Chicago v. IWCC 1-09-2320WC, filed 4-11-11
2 DA’s & (consolidated)
: 20% loss MAW
5-5-04: wage-differential
Affirmed by IWCC & confirmed by Circuit Court
Appellate Court: “statutory interpretation” therefore “de novo”
“Claimant is not entitled to an award under both section 8(d)1 and section 8(d)2 for the same condition of ill-being.”
Need evidence to “delineate and apportion the nature and extent of permanency attributable to each accident.”
Dissent: manifest weight

3. Baumgardner v. IWCC 1-10-0727WC, filed 4-11-11
3 DA’s ; ; (consolidated)
One wage-differential award by Arbitrator, no separate specific loss for injury
Commission affirmed and Circuit Court confirmed
Appellate Court: “manifest weight”
“Commission properly evaluated the totality of the evidence as it related to the claimant’s overall condition of ill-being at the time of the hearing and entered a single award that encompassed the full extent of the disability”