The Illinois Appellate Court recently upheld a workers’ compensation award for an injured factory worker in Durable Packaging v. Illinois Workers’ Compensation Commission. The worker, Rosalba Soto, filed claims for injuries sustained while working at Durable Packaging, a company that manufactures aluminum trays and pans.
Soto alleged she suffered injuries to her right arm, shoulder, and neck when boxes fell on her on two separate occasions – February 11, 2013 and June 17, 2014. After a hearing, the Workers’ Compensation Commission found Soto proved she suffered accidental injuries arising out of her employment on those dates. The Commission further found a causal connection between the accidents and Soto’s current condition. It awarded her temporary disability benefits, medical expenses, and permanent partial disability benefits.
Durable Packaging appealed the Commission’s decision, arguing it was against the manifest weight of the evidence. The appellate court disagreed and affirmed the awards. It noted that the Commission found Soto’s testimony credible and supported by medical records and a surveillance video. The court explained it would not overturn the Commission’s factual findings as long as there was sufficient evidence to support them.
The court also rejected the employer’s argument that the Commission erred in finding causation without expert testimony on the mechanism of injury. It stated medical evidence is not always required to prove causation if the facts and circumstances support a connection. Here, the Commission properly relied on Soto’s testimony and her treating physicians’ opinions.
This case highlights the difficulty for employers in overturning Workers’ Compensation Commission decisions on appeal. Appellate courts will generally defer to the Commission’s findings regarding the credibility of witnesses and the weight of the evidence. As long as there is evidence in the record that reasonably supports the Commission’s determinations, courts will affirm the awards. This upholds the purpose of workers’ compensation laws to provide prompt and equitable compensation for employees injured at work.
