Court Maintains Manifest-Error Standard of Review for IWCC Decisions

The Illinois Appellate Court declined to apply a clearly erroneous standard of review to a decision of the Workers’ Compensation Commission, finding that a manifest error standard applied to the commission’s resolution of a dispute over the cause of a nurse’s shoulder problems. Case: Rechenberg v. IWCC (Centegra Memorial Medical Center), No. 16-MR-205, 03/08/2018, published. Facts: Debra M. Rechenberg worked as a registered nurse for the Centegra Memorial Medical Center. She allegedly injured her shoulder while at work on Jan. 18, 2014. This allegedly injury happened not l...