Bremer v. City of Rockford
Annotate this CasePlaintiff was hired as a Rockford firefighter in 1976. In 2004, plaintiff successfully sought an occupational disease disability pension under 40 ILCS 5/4-110.1, by establishing that he was a firefighter with five or more years of service who was unable to perform his duties due to heart disease resulting from his service as a firefighter. The city paid his health insurance premiums through February 2008, as required by ordinance. Plaintiff sought continuing health insurance benefits under Section 10 of the Benefits Act, which provides premium-free health insurance benefits for a public safety employee, his spouse, and dependent children, when the employee is catastrophically injured or killed in the line of duty under specified circumstances, 820 ILCS 320/10. The city determined that receipt of an occupational disease disability pension did not establish that plaintiff suffered a catastrophic injury. Plaintiff sought a declaratory judgment that the award of an occupational disease disability pension establishes a catastrophic injury. The circuit court determined that plaintiff was entitled to continuing benefits. The appellate court agreed Section 10(a)’s “catastrophic injury” requirement was satisfied by the award of a Section 4-110.1 occupational disease disability pension, but remanded, holding that there was a question of material fact on the Section 10(b) element of whether plaintiff’s injury resulted from his response to what was reasonably believed to be an emergency. The Illinois Supreme Court affirmed, but vacated the remand. The court previously held that a Section 10(a) “catastrophic injury” is synonymous with an injury resulting in a Section 4-110 line-of-duty disability pension. In this case, the court concluded that “catastrophic injury” is not synonymous with an injury resulting in an occupational disease disability pension.
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