Primary Jurisdiction Doctrine Can't Be Used to Stay IWCC Proceedings

The Illinois Supreme Court unanimously ruled that the primary jurisdiction doctrine cannot be used by a trial judge to enter an order staying an administrative proceeding in the Illinois Workers’ Compensation Commission. Case: West Bend Mutual Insurance Co. v. TRRS Corp., No. 124690, 01/24/2020, published. Facts and procedural history: In October 2018, the West Bend Mutual Insurance Co. filed a complaint seeking a declaratory judgment against the TRRS Corp. West Bend alleged that it issued a workers’ compensation and liability insurance policy to TRRS effective from June 20, 201...