On October 15, 2014 the First District Appellate Court issued its Rule 23 Order in Quinlan v. Board of Trustees of the Elk Grove Village Firefighters’ Pension Fund. The appellate court affirmed the Pension Board’s decision denying the plaintiff’s application for a disability pension. Three separate doctors concluded that the plaintiff was not permanently disabled. An FCE also concluded that the plaintiff could perform the duties of a firefighter. The appellate court therefore concluded that the Pension Board’s decision was not against the manifest weight of the evidence.
On July 23, 2014 the Second District Appellate Court issued its Opinion in Village of Vernon Hills v. Heelan. The appellate court held that the Village was required to pay the defendant’s health insurance premiums pursuant to PSEBA after the police pension board awarded defendant a line of duty disability pension. The defendant slipped and injured his hip while responding to a panic call alarm. The appellate court, citing the Supreme Court’s holding in Krohe, held that the award of a line of duty disability pension satisfies the catastrophic injury requirement in section 10(a) of PSEBA. The Village argued that it should have been able to conduct discovery and present evidence with respect to whether the defendant’s injury was actually catastrophic. The appellate court rejected the argument.