{ "id": 173561, "name": "HASKELL GREEN, Appellant, v. THE INDUSTRIAL COMMISSION et al. (Schadler Enterprises et al., Appellees)", "name_abbreviation": "Green v. Industrial Commission", "decision_date": "1999-08-17", "docket_number": "No. 3-98-0009WC", "first_page": "271", "last_page": "284", "citations": [ { "type": "official", "cite": "307 Ill. App. 3d 271" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "668 So. 2d 775", "category": "reporters:state_regional", "reporter": "So. 2d", "case_ids": [ 7438354 ], "weight": 2, "year": 1995, "pin_cites": [ { "page": "778-79" } ], "opinion_index": 0, "case_paths": [ "/so2d/668/0775-01" ] }, { "cite": "172 F.2d 542", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 1182492 ], "weight": 2, "year": 1949, "pin_cites": [ { "page": "546" } ], "opinion_index": 0, "case_paths": [ "/f2d/172/0542-01" ] }, { "cite": "8 U.S.F. Mar. L.J. 185", "category": "journals:journal", "reporter": "U.S.F. Mar. L.J", "year": 1996, "pin_cites": [ { "parenthetical": "arguing that doctrines of preemption and supersession preclude application of state workers' compensation laws to seamen" } ], "opinion_index": 0 }, { "cite": "636 A.2d 1313", "category": "reporters:state_regional", "reporter": "A.2d", "case_ids": [ 7376887 ], "weight": 3, "year": 1994, "pin_cites": [ { "page": "1317-18", "parenthetical": "noting that Supreme Court has never abrogated Jensen as it relates to seamen covered by the Jones Act" }, { "page": "1317" }, { "page": "1317" } ], "opinion_index": 0, "case_paths": [ "/a2d/636/1313-01" ] }, { "cite": "33 U.S.C. \u00a7 903", "category": "laws:leg_statute", "reporter": "U.S.C.", "pin_cites": [ { "page": "(a)" } ], "opinion_index": 0 }, { "cite": "370 U.S. 114", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6165684 ], "weight": 6, "year": 1962, "pin_cites": [ { "page": "126-27" }, { "page": "376-77" }, { "page": "1203" } ], "opinion_index": 0, "case_paths": [ "/us/370/0114-01" ] }, { "cite": "44 Stat. 1426", "category": "laws:leg_session", "reporter": "Stat.", "opinion_index": 0 }, { "cite": "317 U.S. 249", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 304034 ], "weight": 15, "year": 1942, "pin_cites": [ { "page": "256" }, { "page": "250" }, { "page": "229" }, { "page": "254" }, { "page": "249" }, { "page": "228" }, { "page": "253" }, { "page": "248-49" }, { "page": "227" }, { "page": "253" }, { "page": "248" }, { "page": "227" }, { "page": "255-56" }, { "page": "250" }, { "page": "228-29" } ], "opinion_index": 0, "case_paths": [ "/us/317/0249-01" ] }, { "cite": "33 U.S.C. \u00a7 901", "category": "laws:leg_statute", "reporter": "U.S.C.", "year": 1994, "pin_cites": [ { "page": "et seq." } ], "opinion_index": 0 }, { "cite": "236 Miss. 51", "category": "reporters:state", "reporter": "Miss.", "case_ids": [ 1315146 ], "weight": 4, "year": 1959, "pin_cites": [ { "page": "64" }, { "page": "543" }, { "page": "64", "parenthetical": "noting that no Supreme Court case has ever applied state law to a \"seaman\"" }, { "page": "543", "parenthetical": "noting that no Supreme Court case has ever applied state law to a \"seaman\"" } ], "opinion_index": 0, "case_paths": [ "/miss/236/0051-01" ] }, { "cite": "365 So. 2d 1192", "category": "reporters:state_regional", "reporter": "So. 2d", "case_ids": [ 9634638 ], "weight": 3, "year": 1979, "pin_cites": [ { "page": "1195" }, { "page": "1195" } ], "opinion_index": 0, "case_paths": [ "/so2d/365/1192-01" ] }, { "cite": "635 P.2d 1182", "category": "reporters:state_regional", "reporter": "P.2d", "case_ids": [ 10441288, 10441304 ], "weight": 3, "year": 1981, "pin_cites": [ { "page": "1185-86", "parenthetical": "observing that \"where the facts *** show a claimant engaged in wholly maritime work, the courts have declined to lengthen the shadow of the twilight zone, and have remitted the claimants to their federal remedies\"" }, { "page": "1185" } ], "opinion_index": 0, "case_paths": [ "/p2d/635/1182-01", "/p2d/635/1182-02" ] }, { "cite": "184 W. Va. 673", "category": "reporters:state", "reporter": "W. Va.", "case_ids": [ 8578818 ], "weight": 8, "year": 1991, "pin_cites": [ { "page": "677", "parenthetical": "finding that the Jones Act is the exclusive remedy for seamen and that, as such, West Virginia's workers' compensation act was inapplicable" }, { "page": "421", "parenthetical": "finding that the Jones Act is the exclusive remedy for seamen and that, as such, West Virginia's workers' compensation act was inapplicable" }, { "page": "677" }, { "page": "421" }, { "page": "676-77" }, { "page": "420-21" } ], "opinion_index": 0, "case_paths": [ "/w-va/184/0673-01" ] }, { "cite": "153 So. 2d 81", "category": "reporters:state_regional", "reporter": "So. 2d", "case_ids": [ 9835432 ], "weight": 3, "year": 1963, "pin_cites": [ { "page": "86" }, { "page": "86" } ], "opinion_index": 0, "case_paths": [ "/so2d/153/0081-01" ] }, { "cite": "330 Ill. App. 141", "category": "reporters:state", "reporter": "Ill. App.", "case_ids": [ 3412419 ], "weight": 2, "year": 1947, "pin_cites": [ { "page": "146" } ], "opinion_index": 0, "case_paths": [ "/ill-app/330/0141-01" ] }, { "cite": "264 U.S. 219", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6139729 ], "weight": 9, "year": 1924, "pin_cites": [ { "page": "225" }, { "page": "651-52" }, { "page": "304" }, { "page": "225" }, { "page": "652" }, { "page": "304" } ], "opinion_index": 0, "case_paths": [ "/us/264/0219-01" ] }, { "cite": "253 U.S. 149", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 189345 ], "weight": 3, "year": 1920, "opinion_index": 0, "case_paths": [ "/us/253/0149-01" ] }, { "cite": "28 U.S.C. \u00a7 1333", "category": "laws:leg_statute", "reporter": "U.S.C.", "year": 1994, "pin_cites": [ { "parenthetical": "containing the \"saving to suitors\" clause in its current form" } ], "opinion_index": 0 }, { "cite": "447 U.S. 715", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6188834 ], "weight": 24, "year": 1980, "pin_cites": [ { "page": "717" }, { "page": "461" }, { "page": "2435" }, { "page": "717" }, { "page": "461" }, { "page": "2435" }, { "page": "717-18" }, { "page": "461" }, { "page": "2435" }, { "page": "717-18" }, { "page": "461" }, { "page": "2435" }, { "page": "718" }, { "page": "461" }, { "page": "2435" }, { "page": "717-18" }, { "page": "461" }, { "page": "2435" }, { "page": "719" }, { "page": "462" }, { "page": "2436" }, { "page": "719-20" }, { "page": "462-63" }, { "page": "2436" } ], "opinion_index": 0, "case_paths": [ "/us/447/0715-01" ] }, { "cite": "281 U.S. 38", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 3913318 ], "weight": 9, "year": 1930, "pin_cites": [ { "parenthetical": "Court held seamen could no longer maintain a state wrongful death action after the Jones Act was enacted" }, { "parenthetical": "Court held seamen could no longer maintain a state wrongful death action after the Jones Act was enacted" }, { "parenthetical": "Court held seamen could no longer maintain a state wrongful death action after the Jones Act was enacted" }, { "page": "46" }, { "page": "692" }, { "page": "211" }, { "page": "46" }, { "page": "692" }, { "page": "211" } ], "opinion_index": 0, "case_paths": [ "/us/281/0038-01" ] }, { "cite": "6 U.S.F. Mar. L.J. 547", "category": "journals:journal", "reporter": "U.S.F. Mar. L.J", "year": 1994, "pin_cites": [ { "page": "592-93", "parenthetical": "although percentage evidence is not conclusive, the worker must perform a significant part of his work aboard a vessel" } ], "opinion_index": 0 }, { "cite": "708 So. 2d 878", "category": "reporters:state_regional", "reporter": "So. 2d", "case_ids": [ 11856840 ], "year": 1998, "pin_cites": [ { "page": "883", "parenthetical": "\"change person\" working on a floating casino found not to be a seaman because her relationship with the vessel was too temporal where she only worked on it when it was docked and consequently was not exposed to the perils of the sea" } ], "opinion_index": 0, "case_paths": [ "/so2d/708/0878-01" ] }, { "cite": "230 Ill. App. 3d 657", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5211746 ], "year": 1992, "pin_cites": [ { "page": "660", "parenthetical": "reviewing court will only disturb the Commission's determination of fact where it is against the manifest weight of the evidence" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/230/0657-01" ] }, { "cite": "143 F. Supp. 73", "category": "reporters:federal", "reporter": "F. Supp.", "case_ids": [ 4270672 ], "year": 1956, "opinion_index": 0, "case_paths": [ "/f-supp/143/0073-01" ] }, { "cite": "302 F. Supp. 630", "category": "reporters:federal", "reporter": "F. Supp.", "case_ids": [ 3001916 ], "year": 1969, "opinion_index": 0, "case_paths": [ "/f-supp/302/0630-01" ] }, { "cite": "428 F.2d 40", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 2240134 ], "year": 1970, "opinion_index": 0, "case_paths": [ "/f2d/428/0040-01" ] }, { "cite": "498 U.S. 337", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6225911 ], "weight": 12, "year": 1991, "pin_cites": [ { "page": "354" }, { "page": "882" }, { "page": "817" }, { "page": "343-45" }, { "page": "874-76" }, { "page": "811-12" }, { "page": "345" }, { "page": "876" }, { "page": "812" }, { "page": "344" }, { "page": "875" }, { "page": "812" } ], "opinion_index": 0, "case_paths": [ "/us/498/0337-01" ] }, { "cite": "266 F.2d 769", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 1977298 ], "year": 1959, "pin_cites": [ { "page": "779" } ], "opinion_index": 0, "case_paths": [ "/f2d/266/0769-01" ] }, { "cite": "515 U.S. 347", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 1563685 ], "weight": 33, "year": 1995, "pin_cites": [ { "page": "354" }, { "page": "328" }, { "page": "2183" }, { "page": "368-69" }, { "page": "337-38" }, { "page": "2190" }, { "page": "368" }, { "page": "337" }, { "page": "2190" }, { "page": "368" }, { "page": "337" }, { "page": "2190" }, { "page": "368" }, { "page": "337" }, { "page": "2190" }, { "page": "368" }, { "page": "337" }, { "page": "2190" }, { "page": "370" }, { "page": "338" }, { "page": "2190" }, { "page": "369" }, { "page": "338" }, { "page": "2190" }, { "page": "370" }, { "page": "338" }, { "page": "2190-91" }, { "page": "369" }, { "page": "338" }, { "page": "2190", "parenthetical": "determining seaman status in conjunction with the appropriate standard is a question left to the fact finder" }, { "page": "371" }, { "page": "339" }, { "page": "2191", "parenthetical": "an appropriate rule of thumb is that a worker who spends less than approximately 30% of his work time on a vessel is not a seaman" } ], "opinion_index": 0, "case_paths": [ "/us/515/0347-01" ] }, { "cite": "244 U.S. 205", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 343089 ], "weight": 24, "year": 1917, "pin_cites": [ { "page": "215" }, { "page": "1098" }, { "page": "528-29" }, { "page": "215" }, { "page": "1098" }, { "page": "528-29" }, { "page": "215" }, { "page": "1098" }, { "page": "528-29" }, { "page": "216" }, { "page": "1098" }, { "page": "529", "parenthetical": "providing examples that a lien may be placed upon a vessel pursuant to state statute, pilotage fees may be fixed by state law, and wrongful death actions may be provided under state law" }, { "page": "215" }, { "page": "1098" }, { "page": "528" }, { "page": "216" }, { "page": "1098" }, { "page": "529" }, { "page": "216" }, { "page": "1098" }, { "page": "529", "parenthetical": "no state legislation can validly be applied \"if it contravenes the essential purpose expressed by an act of Congress *** or interferes with the proper harmony and uniformity of\" maritime law" } ], "opinion_index": 0, "case_paths": [ "/us/244/0205-01" ] } ], "analysis": { "cardinality": 1489, "char_count": 35960, "ocr_confidence": 0.817, "pagerank": { "raw": 4.03580807328026e-08, "percentile": 0.006826073643675751 }, "sha256": "086bae588f68b653fd9de1bfd39c13785540f0d511346820af924175421ba658", "simhash": "1:e3e83f1ac31e90df", "word_count": 5990 }, "last_updated": "2023-07-14T21:00:41.446378+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "HASKELL GREEN, Appellant, v. THE INDUSTRIAL COMMISSION et al. (Schadler Enterprises et al., Appellees)." ], "opinions": [ { "text": "JUSTICE RAKOWSKI\ndelivered the opinion of the court:\nThis case raises a question of jurisdiction involving the tension between competing policies of federal and state law. The question is whether claimant Haskel Green, an injured seaman, may pursue workers\u2019 compensation benefits under the Workers\u2019 Compensation Act (Act) (820 ILCS 305/1 et seq. (West 1998)) or whether he is limited to benefits under federal law, specifically, the Merchant Marine Act (Jones Act) (46 U.S.C. app. \u00a7 688 (1994)). The arbitrator found that the Jones Act was claimant\u2019s exclusive means of recovery, precluding application of the Workers\u2019 Compensation Act. Adopting the arbitrator\u2019s decision, the Industrial Commission (Commission) affirmed, a decision that was confirmed on administrative review.\nAlthough the Commission\u2019s decision will cause claimant to fall into a void of coverage lying between federal and state law remedies, we nonetheless find that claimant\u2019s status as a seaman precludes application of the Act in this case. We therefore affirm.\nI. Background\nClaimant was employed by Schadler Enterprises and Joe Schadler (collectively employer) as an entertainer on employer\u2019s Queen of Hearts Showboat (Queen of Hearts). The Queen of Hearts is a 400-passenger excursion boat. It was docked in Moline, Illinois, and traveled the Mississippi and the Ohio Rivers. Dinner cruises lasted about 2V2 hours and traversed 15 to 16 miles. The longest cruises stretched as far as 75 to 100 miles.\nClaimant began working for employer in 1990, at which time he also signed a contract. Claimant typically performed his show, the \u201cBuddy Green Show,\u201d on dinner cruises. His contract required him to be available for two shows a night, six nights a week. Claimant did not sleep or eat on the Queen of Hearts; nor did he have a dressing room.\nIn addition to performing on the boat, claimant did promotional work for employer that took him on land. He recorded radio and television commercials to promote the Queen of Hearts, requiring some work to be performed on land as well as on the boat. He also photographed some of employer\u2019s attractions including the Queen of Hearts, a tram on Arsenal Island, and the Jubilee. These photographs were placed in pamphlets advertising employer\u2019s attractions. Other land-based work included positioning guests boarding the boat for photographs during the 1990 showboat season, negotiating the photograph development agreement for the development of these photographs, and making a phone call on behalf of the employer regarding a dispute. However, employer did not reimburse claimant for these extra services.\nClaimant further claimed that he performed his show on land both during the off-season and a couple of times during the season at employer\u2019s request. However, the testimony of employer and Robin Lindley of Quad City Attractions indicates that, at the most, employer directed or paid claimant to perform two shows prior to 1991 out of an approximate total of 14 shows that claimant performed on land while Ms. Lindley organized and paid claimant for almost all of the other land-based shows. Claimant contracted and dealt separately with Ms. Lindley. The only benefit realized by employer from the shows he did not arrange was that those who saw them might book cruises on the Queen of Hearts through Ms. Lindley\u2019s Quad City Attractions business. Ms. Lindley testified that she was not reimbursed by employer and that employer was not a party to any contracts between her and claimant.\nOn September 23, 1993, claimant experienced low back pain while doing an Elvis Presley imitation during a performance. On October 9, 1993, during a dinner cruise performance, claimant again suffered severe low back pain and spasms, causing him to collapse on stage. Following the accident, he began treatment with a neurosurgeon and subsequently underwent back surgery and physical therapy. Claimant has not been released to return to work.\nClaimant received some benefits under the Jones Act. Specifically, he has received approximately $1,500 in maintenance and approximately $37,000 in cure for medical bills.\nII. Analysis\nAs stated at the beginning, this case reveals the tension in determining whether an injured maritime employee is limited to recovery under the Jones Act or whether he can seek workers\u2019 compensation under Illinois law. In answering this question, we first conclude that claimant is a seaman and that the Jones Act would therefore apply exclusively. We, however, then address claimant\u2019s contention that he falls into a \u201ctwilight zone\u201d of jurisdiction and that, as a result, he should be entitled to workers\u2019 compensation benefits. This argument, which has been made numerous times before other courts, must be rejected. Although we believe this case presents important reasons to permit recovery under the workers\u2019 compensation laws of Illinois, like the courts before us, we conclude that we are without the power to do so.\nA. The Jones Act and Claimant\u2019s Seaman Status\nIn his reply brief, claimant seemingly admits that he is a seaman even though he makes a great effort to outline all the land-based work he allegedly performed for employer. Nevertheless, because we ultimately conclude that injured seamen cannot recover under the Workers\u2019 Compensation Act, we therefore elect to give his status careful consideration.\nPrior to 1920, seamen could only recover pursuant to general maritime law as accepted by the federal courts. Southern Pacific Co. v. Jensen, 244 U.S. 205, 215, 61 L. Ed. 1086, 1098, 37 S. Ct. 524, 528-29 (1917); 2 M. Norris, The Law of Seamen \u00a7 30:2, at 326 (4th ed. 1985) (hereinafter The Law of Seamen). Those remedies included maintenance and cure and damages for injuries caused by the unseaworthiness of a vessel. Chandris, Inc. v. Latsis, 515 U.S. 347, 354, 132 L. Ed. 2d 314, 328, 115 S. Ct. 2172, 2183 (1995). However, in 1920, Congress promulgated the Jones Act to provide seamen the additional right to seek damages for negligence. Part (a) of the Jones Act provides:\n\u201cAny seaman who shall suffer personal injury in the course of his. employment may, at his election, maintain an action for damages at law, with the right of trial by jury, and in such action all statutes of the United States modifying or extending the common-law right or remedy in cases of personal injury to railway employees shall apply ***.\u201d 46 U.S.C. app. \u00a7 688 (1994).\nConspicuously missing from the Jones Act is a definition of \u201cseaman.\u201d Consequently, the task of defining the facts and circumstances under which a worker is considered to be a seaman has been left to the courts both before and after the Jones Act was enacted. Recently, the Supreme Court reviewed the various approaches that have developed and configured the best aspects of these approaches into a two-prong test for determining seaman status. Chandris, Inc., 515 U.S. at 368-69, 132 L. Ed. 2d at 337-38, 115 S. Ct. at 2190. First, the \u201c \u2018employee\u2019s duties must \u201ccontribute] to the function of the vessel or to the accomplishment of its mission.\u201d \u2019 \u201d Chandris, Inc., 515 U.S. at 368, 132 L. Ed. 2d at 337, 115 S. Ct. at 2190, quoting Offshore Co. v. Robinson, 266 F.2d 769, 779 (5th Cir. 1959). This requirement is broad, as the Court, noted: \u201c \u2018All who work at sea in the service of a ship\u2019 are eligible for seaman status.\u201d (Emphasis in original.) Cham dris, Inc., 515 U.S. at 368, 132 L. Ed. 2d at 337, 115 S. Ct. at 2190, quoting McDermott International, Inc. v. Wilander, 498 U.S. 337, 354, 112 L. Ed.-2d 866, 882, 111 S. Ct. 807, 817 (1991). The second prong requires that the employee must have a substantial connection in both duration and nature to a vessel or an identifiable group of vessels in navigation. Chandris, Inc., 515 U.S. at 368, 132 L. Ed. 2d at 337, 115 S. Ct. at 2190. The Court explained the significance of this inquiry, stating:\n\u201cThe fundamental purpose of this substantial connection requirement is to give full effect to the remedial scheme created by Congress and to separate the sea-based maritime employees who are entitled to Jones Act protection from those land-based workers who have only a transitory or sporadic connection to a vessel in navigation, and therefore whose employment does not regularly expose them to the perils of the sea.\u201d Chandris, Inc., 515 U.S. at 368, 132 L. Ed. 2d at 337, 115 S. Ct. at 2190.\nThe substantial connection requirement developed as result of certain federal courts\u2019 de facto abandonment and the Supreme Court\u2019s ultimate rejection of the \u201caid in navigation\u201d test, which required the worker to contribute to the vessel\u2019s navigation. Wilander, 498 U.S. at 343-45, 112 L. Ed. 2d at 874-76, 111 S. Ct. at 811-12; see E. Bull III, Seaman Status Revisited: A Practical Guide to Status Determination, 6 U.S.E Mar. L.J. 547, 562-73 (1994) (discussing certain circuit courts\u2019 approaches to or departure from the \u201caid in navigation\u201d test); see also 1 T. Schoenbaum, Admiralty and Maritime Law \u00a7 6-9, at 257 (2d ed. 1994) (hereinafter Maritime Law) (concluding that the Court rejected the \u201caid in navigation\u201d test on three bases \u2014 past authorities\u2019 usage of \u201cseaman\u201d as a term of art, congressional intent, and the Court\u2019s own case law). In abandoning the \u201caid in navigation\u201d requirement, the Supreme Court observed that many courts had conferred seaman status upon persons who performed sundry jobs that were more specific to the furtherance of the vessel\u2019s enterprise than they were to the vessel\u2019s navigation. Wilander, 498 U.S. at 345, 112 L. Ed. 2d at 876, 111 S. Ct. at 812. Such cases found a magician, musician, cook, waiter, engineer, hairdresser, barber, radio operator, telephone operator, chambermaid, and carpenter to be seamen. See Wilander, 498 U.S. at 344, 112 L. Ed. 2d at 875, 111 S. Ct. at 812; Bunn v. Global Marine, Inc., 428 F.2d 40 (5th Cir. 1970); Brinegar v. San Ore Construction Co., 302 F. Supp. 630 (E.D. Ark. 1969); McAfoos v. Canadian Pacific Steamships, Ltd., 143 F. Supp. 73 (S.D.N.Y. 1956); 1 Maritime Law \u00a7 6-9, at 257; 2 The Law of Seamen \u00a7 30:7, at 354.\nWhen applying the two prongs, the court must weigh the total circumstances of the employee\u2019s employment. Chandris, Inc., 515 U.S. at 370, 132 L. Ed. 2d at 338, 115 S. Ct. at 2190. In doing so, consideration of the second prong ensures that those employees who satisfy the first prong by \u201cdoing the ship\u2019s work\u201d \u201chave the requisite employment-related connection to a vessel in navigation.\u201d Chandris, Inc., 515 U.S. at 369, 132 L. Ed. 2d at 338, 115 S. Ct. at 2190. As such, the test will satisfy the ultimate concern of whether the individual is actually a sea-based employee or merely a land-based employee who happens to be working on a vessel at a given time. See Chandris, Inc., 515 U.S. at 370, 132 L. Ed. 2d at 338, 115 S. Ct. at 2190-91.\nApplication of the two-prong test in this case leads us to conclude that claimant is a seaman within the context of his employ with employer. First, although it cannot be said that claimant contributed to the \u201cfunction\u201d of the Queen of Hearts, claimant clearly had a vital role in the \u201caccomplishment\u201d of her mission. Simply put, claimant provided the entertainment on a showboat. Second, considering that the fundamental purpose of the substantial connection requirement is to preclude application of the Jones Act to those who only have a transitory or sporadic connection to a vessel in navigation and who are not regularly exposed to the perils of the sea, we find the factual circumstances here illustrate a substantial connection in both duration and nature between claimant and the Queen of Hearts. Claimant\u2019s tenure on the Queen of Hearts spanned nearly four seasons. Each season claimant was required to be available for two dinner shows a night, six nights a week. The shows lasted about 21/z hours, traversing 15 to 16 miles on the navigable waterways of either the Mississippi or Ohio River. Longer cruises spanned as far as 75 to 100 miles. Under these facts, we believe claimant\u2019s connection to a vessel in navigation was not sporadic or transitory but, rather, was substantial, causing him to be regularly exposed to the perils of the sea. As such, we agree with the Commission\u2019s conclusion that claimant is a seaman and therefore find that it is not against the manifest weight of the evidence. See Chandris, Inc., 515 U.S. at 369, 132 L. Ed. 2d at 338, 115 S. Ct. at 2190 (determining seaman status in conjunction with the appropriate standard is a question left to the fact finder); Man\u00eds v. Industrial Comm\u2019n, 230 Ill. App. 3d 657, 660 (1992) (reviewing court will only disturb the Commission\u2019s determination of fact where it is against the manifest weight of the evidence).\u2019 Cf. Thompson v. Casino Magic Corp., 708 So. 2d 878, 883 (Miss. 1998) (\u201cchange person\u201d working on a floating casino found not to be a seaman because her relationship with the vessel was too temporal where she only worked on it when it was docked and consequently was not exposed to the perils of the sea).\nWe note that, at most, the record only shows that claimant performed twice on land upon employer\u2019s request. Instead, all the other land-based shows were arranged by Ms. Lindley of Quad City Attractions. That employer inured an indirect benefit .in that some who saw claimant\u2019s road shows might have booked reservations on the Queen of Hearts did not transform claimant\u2019s work for Ms. Lindley into work for employer. Moreover, the amount of time claimant spent on land taking photographs or working on other promotional work was minimal. Consequently, we discount claimant\u2019s road shows and other land-based work as insignificant in light of the criteria set out above. See Chandris, Inc., 515 U.S. at 371, 132 L. Ed. 2d at 339, 115 S. Ct. at 2191 (an appropriate rule of thumb is that a worker who spends less than approximately 30% of his work time on a vessel is not a seaman); see also E. Bull III, Seaman Status Revisited: A Practical Guide to Status Determination, 6 U.S.F. Mar. L.J. 547, 592-93 (1994) (although percentage evidence is not conclusive, the worker must perform a significant part of his work aboard a vessel). The next question we turn to is whether claimant\u2019s seaman status limits recovery against employer to those remedies provided under the Jones Act.\nB. Exclusive Jones Act Jurisdiction\nBefore Congress enacted the Jones Act in 1920 and when the development of maritime law was left to the federal courts, the United States Supreme Court decided the seminal maritime case of Southern Pacific Co., v. Jensen, 244 U.S. 205, 61 L. Ed. 1086, 37 S. Ct. 524 (1917). In Jensen, a stevedore responsible for loading and unloading ships at a dock was fatally injured on a gangway between a ship and the shore. The fatally injured stevedore was not covered by any federal law at the time. Consequently, his widow sought compensation under the state\u2019s workers\u2019 compensation laws.\nIn determining that the state\u2019s workers\u2019 compensation laws were constitutionally precluded from applying to decedent\u2019s death, the Court observed that section 2 of article III of the United States Constitution extended the judicial power of the United States to \u201call Cases of admiralty and maritime Jurisdiction\u201d (U.S. Const., art. Ill, \u00a7 2) while section 8 of article I of the Constitution provides Congress with the power \u201c[t]o make all Laws which shall be necessary and proper for carrying into Execution the foregoing Powers, and all other Powers vested by this Constitution in the Government of the United States, or in any Department or Officer thereof\u2019 (U.S. Const., art. I, \u00a7 8). Jensen, 244 U.S. at 215, 61 L. Ed. at 1098, 37 S. Ct. at 528-29. Based upon these provisions and its prior decisions, the Court stated it was well settled that \u201cCongress has paramount power to fix and determine the maritime law which shall prevail throughout the country\u201d and that \u201cin the absence of some controlling statute the general maritime law as accepted by the federal courts constitutes part of our national law applicable to matters within the admiralty and maritime jurisdiction.\u201d Jensen, 244 U.S. at 215, 61 L. Ed. at 1098, 37 S. Ct. at 528-29. The Court acknowledged that state law will necessarily affect, change, or modify maritime law to some degree. Jensen, 244 U.S. at 216, 61 L. Ed. at 1098, 37 S. Ct. at 529 (providing examples that a lien may be placed upon a vessel pursuant to state statute, pilotage fees may be fixed by state law, and wrongful death actions may be provided under state law); but see Lindgren v. United States, 281 U.S. 38, 74 L. Ed. 686, 50 S. Ct. 207 (1930) (Court held seamen could no longer maintain a state wrongful death action after the Jones Act was enacted). However, it went on to reason that it \u201ccould not have been intended to place the rules and limits of maritime law under the disposal and regulation of the several States, as that would have defeated the uniformity and consistency at which the Constitution aimed on all subjects of a commercial character affecting the intercourse of the States with each other or with foreign states.\u201d Jensen, 244 U.S. at 215, 61 L. Ed. at 1098, 37 S. Ct. at 528. No state \u201clegislation is valid if it contravenes the essential purpose expressed by an act of Congress or works material prejudice to the characteristic features of the general maritime law or interferes with the proper harmony and uniformity of that law in its international and interstate relations.\u201d Jensen, 244 U.S. at 216, 61 L. Ed. at 1098, 37 S. Ct. at 529. \u2022\nIn response to Jensen, Congress made two attempts to delegate authority to the states to enable them to cover maritime workers with their respective workers\u2019 compensation acts by amending the \u201csavings to suitors\u201d clause of the Judiciary Act of 1789. Sun Ship, Inc. v. Pennsylvania, 447 U.S. 715, 717, 65 L. Ed. 2d 458, 461, 100 S. Ct. 2432, 2435 (1980). See also 28 U.S.C. \u00a7 1333 (1994) (containing the \u201csaving to suitors\u201d clause in its current form). Nevertheless, attempts to legislatively overrule Jensen were repudiated by the Court in Knickerbocker Ice Co. v. Stewart, 253 U.S. 149, 64 L. Ed. 834, 40 S. Ct. 438 (1920), and Washington v. W.C. Dawson & Co., 264 U.S. 219, 68 L. Ed. 646, 44 S. Ct. 302 (1924). The Court strongly maintained its position subscribed to in Jensen that the Constitution entrusted the subject of maritime law to Congress to deal with according to its discretion\u2014 \u201cnot for delegation to others.\u201d Washington, 264 U.S. at 225, 68 L. Ed. at 651-52, 44 S. Ct. at 304. It asserted:\n\u201cTo say that because Congress could have enacted a compensation act applicable to maritime injuries, it could authorize the States to do so as they might desire, is false reasoning. Moreover, such an authorization would inevitably destroy the harmony and uniformity which the Constitution not only contemplated but actually established \u2014 it would defeat the very purpose of the grant.\u201d Washington, 264 U.S. at 225, 68 L. Ed. at 652, 44 S. Ct. at 304.\nIn Lindgren, the Court once again maintained the Jensen demarcation line, only this time in the context of the Jones Act. In that case, the Court held a seaman could not maintain a wrongful death action under his state\u2019s law. Although it had allowed such an action under the general maritime law, the Court disregarded the past, observing that once the \u201cCongress has acted, the laws of the States, insofar as they cover the same field, are superseded, for necessarily that which is not supreme must yield to that which is.\u201d Lindgren, 281 U.S. at 46, 74 L. Ed. at 692, 50 S. Ct. at 211.\nIt is the above line of Supreme Court cases that supports the long-standing application of exclusive jurisdiction of the Jones Act to injured seamen. For example, in Hendriksen v. City of Chicago, 330 Ill. App. 141 (1947), the court found that the Illinois Workmen\u2019s Compensation Act (Ill. Rev. Stat. 1945, ch. 48, par. 138 et seq.) could not be applied to a seaman who fell under the ambit of the Jones Act. Upon quoting the above language in Washington, the court held that \u201cthe Illinois Workmen\u2019s Compensation Act could not reach, include nor govern the claims of seamen or members of the crew of a vessel on navigable streams, injured in line of duty.\u201d Hendriksen v. City of Chicago, 330 Ill. App. 141, 146 (1947). Similarly, in Apperson v. Universal Services Inc., 153 So. 2d 81 (La. Ct. App. 1963), the court asserted that the \u201c[cjourts, no less than Congress, are restricted by the Constitution of the United States\u201d and if \u201c[t]he Congress could not constitutionally enact a statute providing injuries sustained by seamen within the scope of their employment might be redressed under States\u2019 Workers\u2019] Compensation laws[,] neither can the courts so decree.\u201d Apperson, 153 So. 2d at 86. Other courts have also held that the Jones Act is a seaman\u2019s exclusive remedy. See, e.g., Indiana & Michigan Electric Co. v. Workers\u2019 Compensation Commissioner, 184 W. Va. 673, 403 S.E.2d 416 (1991); Anderson v. Alaska Packers Ass\u2019n, 635 P.2d 1182 (Alaska 1981); Bearden v. Leon C. Breaux Towing Co., 365 So. 2d 1192 (La. Ct. App. 1979); Valley Towing Co. v. Allen, 236 Miss. 51, 64, 109 So. 2d 538, 543 (1959). Thus, it appears clear to this court that claimant is limited to the remedies provided under the Jones Act.\nHowever, because recovery under the Jones Act requires a showing of fault, claimant, like so many other injured seamen who cannot receive adequate compensation under the Jones Act, attempts to borrow the \u201ctwilight zone\u201d doctrine developed within the context of the Longshoremen\u2019s and Harbor Workers\u2019 Compensation Act (Longshoremen\u2019s Act) (33 U.S.C. \u00a7 901 et seq. (1994)) and apply it to this case. Where the \u201ctwilight zone\u201d doctrine is properly invoked in the Longshoremen\u2019s Act context, the injured employee may elect to pursue either Longshoremen\u2019s Act remedies or state workers\u2019 compensation remedies. As will be seen below, however, this doctrine of concurrent jurisdiction has no application to seamen.\nC. The Inapplicability of the \u201cTwilight Zone\u201d Doctrine to Seamen At the same time the Supreme Court was invalidating Congress\u2019 attempts to delegate compensatory authority to the states, the Court reformed the Jensen doctrine by \u201cidentifying circumstances in which the subject of litigation might be maritime yet \u2018local in character,\u2019 and thus amenable to relief under state law.\u201d Sun Ship, Inc. v. Pennsylvania, 447 U.S. 715, 717, 65 L. Ed. 2d 458, 461, 100 S. Ct. 2432, 2435 (1980). In that same vein, Congress in 1927 successfully extended protection to marine workers excluded by Jensen from recovering under state workers\u2019 compensation laws by enacting the workers\u2019 compensation scheme provided in the Longshoremen\u2019s Act. Sun Ship, Inc., 447 U.S. at 717-18, 65 L. Ed. 2d at 461, 100 S. Ct. at 2435. Congress also integrated the Jensen demarcation line into the Longshoremen\u2019s Act as the boundary where federal remedies gave way to state remedies. See Davis v. Department of Labor, 317 U.S. 249, 256, 87 L. Ed. 246, 250, 63 S. Ct. 225, 229 (1942). As such, where the subject matter of the suit was \u201cmaritime but local,\u201d application of state law remedies was constitutionally permissible. The portion of the Longshoremen\u2019s Act so providing stated that \u201c \u2018[Compensation shall by payable [for an injury] ... occurring upon the navigable waters of the United States ... if recovery ... through workmen\u2019s compensation proceedings may not validly be provided by State law.\u2019 44 Stat. 1426.\u201d Sun Ship, Inc., 447 U.S. at 717-18, 65 L. Ed. 2d at 461, 100 S. Ct. at 2435. From this statutory language, the \u201ctwilight zone\u201d was ultimately born.\nThe boundary between where federal remedies gave way to state law remedies proved to be murky at best in individual cases. As such, the costs were high if the wrong forum was chosen given the various consequence of an incorrect choice, such as the running of a statute of limitations. Davis, 317 U.S. at 254, 87 L. Ed. at 249, 63 S. Ct. at 228. \u201cAfter a decade and a half during which there had not been formulated \u2018any guiding, definite rule to determine the extent of state power in advance of litigation,\u2019 [citation], the Court determined that the border between [the Longshoremen\u2019s Act] and state compensation schemes was less a line than a \u2018twilight zone,\u2019 in which \u2018employees must have their rights determined case by case ***.\u2019 \u201d Sun Ship, Inc., 447 U.S. at 718, 65 L. Ed. 2d at 461, 100 S. Ct. at 2435, quoting Davis, 317 U.S. at 253, 87 L. Ed. at 248-49, 63 S. Ct. at 227. In Davis, the Court effectively established a regime of concurrent jurisdiction within the \u201ctwilight zone.\u201d Sun Ship, Inc., 447 U.S. at 717-18, 65 L. Ed. 2d at 461, 100 S. Ct. at 2435; Davis, 317 U.S. at 253, 87 L. Ed. at 248, 63 S. Ct. at 227. This allowed an injured employee to elect between the Longshoremen\u2019s Act or state workers\u2019 compensation law if there was doubt as to whether the subject of the litigation was purely maritime and covered under the Longshoremen\u2019s Act or maritime but local and therefore compensable under state law. Davis, 317 U.S. at 255-56, 87 L. Ed. at 250, 63 S. Ct. at 228-29. In Calbeck v. Travelers Insurance Co., 370 U.S. 114, 8 L. Ed. 2d 368, 82 S. Ct. 1196 (1962), the Court further elaborated as to the extent of the concurrent jurisdiction regime, asserting:\n\u201cWe conclude that Congress used the phrase \u2018if recovery *** may not validly be provided by State law\u2019 in a sense consistent with the delineation of coverage as reaching injuries occurring on navigable waters. By that language Congress reiterated that the Act reached all those cases of injury to employees on navigable waters as to which Jensen, Knickerbocker and Dawson had rendered questionable the availability of a state compensation remedy. Congress brought under the coverage of the Act all such injuries whether or not a particular one was also within the constitutional reach of a state workmen\u2019s compensation law.\u201d (Emphasis added.) Calbeck, 370 U.S. at 126-27, 8 L. Ed. 2d at 376-77, 82 S. Ct. at 1203.\nConsequently, the jurisdictional makeup for shoremen and harbor workers\u2019 claims consisted of three \u201cjurisdictional spheres\u201d:\n\u201cAt the furthest extreme, Jensen commanded that nonlocal maritime injuries fall under the LHWCA. \u2018Maritime but local\u2019 injuries \u2018upon the navigable waters of the United States,\u2019 33 U.S.C. \u00a7 903(a), could be compensated under the LHWCA or under state law. And injuries suffered beyond navigable waters \u2014 albeit within the range of federal admiralty jurisdiction \u2014 were remediable only under state law.\u201d Sun Ship, Inc., 447 U.S. at 719, 65 L. Ed. 2d at 462, 100 S. Ct. at 2436.\nTherefore, the \u201ctwilight zone\u201d doctrine grew out of the conundrum arising from application of the Longshoremen\u2019s Act. Most courts that have considered the applicability of the \u201ctwilight zone\u201d doctrine to the Jones Act context have declined to apply it, concluding that the Jones Act exclusively provides the remedies for seamen\u2019s work-related injuries. See Benders v. Board of Governors for Higher Education, 636 A.2d 1313, 1317-18 (R.I. 1994) (noting that Supreme Court has never abrogated Jensen as it relates to seamen covered by the Jones Act); Indiana & Michigan Electric Co. v. Workers\u2019 Compensation Commissioner, 184 W. Va. 673, 677, 403 S.E.2d 416, 421 (1991) (finding that the Jones Act is the exclusive remedy for seamen and that, as such, West Virginia\u2019s workers\u2019 compensation act was inapplicable); Anderson, 635 P.2d at 1185-86 (observing that \u201cwhere the facts *** show a claimant engaged in wholly maritime work, the courts have declined to lengthen the shadow of the twilight zone, and have remitted the claimants to their federal remedies\u201d); Bearden v. Leon C. Breaux Towing Co., 365 So. 2d 1192, 1195 (La. Ct. App. 1979) (concluding that \u201cthe line drawn by Jensen still remains, and because we are dealing with a \u2018seaman\u2019 who may sue under the Jones Act, it is constitutionally mandated that plaintiff *** may not have\u201d workers\u2019 compensation benefits, while also asserting that the case presented \u201ca situation which is wholly maritime, far removed from any possible \u2018twilight zone,\u2019 even if such a zone exists for \u2018seamen\u2019 \u201d); Apperson v. Universal Services, Inc., 153 So. 2d 81, 86 (La. Ct. App. 1963) (holding that since parties concede that claimant is a seaman, \u201c[cjlearly there is no twilight zone in which Plaintiff may seek relief under our Workers\u2019] Compensation Law for the factual situation presents an issue wherein the Constitution of the United States obliterates the right of the State to grant to a seaman injured within the scope of his employment relief under the State Workers\u2019] Compensation Act, making exclusive the Federal Courts the forum to Plaintiff\u201d); Valley Towing Co. v. Allen, 236 Miss. 51, 64, 109 So. 2d 538, 543 (1959) (noting that no Supreme Court case has ever applied state law to a \u201cseaman\u201d).\nLikewise, we decline to apply \u201ctwilight zone\u201d concurrent jurisdiction to an employee who is a seaman. Arguably there are some important local concerns that would merit application of the Workers\u2019 Compensation Act in this case. But the circumstances that necessitated the creation of \u201ctwilight zone\u201d jurisdiction in the context of the Longshoremen\u2019s Act are not present in the Jones Act context. As discussed above, the Longshoremen\u2019s Act was designed to allow application of state workers\u2019 compensation law to injured maritime workers under constitutionally permissible circumstances. It was this feature that created the jurisdictional quandary that led to the creation of the \u201ctwilight zone.\u201d This is not the case under the Jones Act. The Jones Act clearly defines the class of workers it covers, namely, seamen, and it does not contain any language suggesting it was meant to complement state workers\u2019 compensation schemes or any other state law. See Indiana & Michigan Electric Co., 184 W. Va. at 677, 403 S.E.2d at 421. Accordingly, we conclude that where the employee is determined to be a seaman, the Jones Act preempts state law and constrains the seaman to its remedies. Indiana & Michigan Electric Co., 184 W. Va. at 676-77, 403 S.E.2d at 420-21; Bearden, 365 So. 2d at 1195; see Benders, 636 A.2d at 1317; Anderson, 635 P.2d at 1185. See generally C. Davis, Federal Supersession of State Workers\u2019 Compensation Acts As Applied to Jones Act Seamen, 8 U.S.F. Mar. L.J. 185 (1996) (arguing that doctrines of preemption and supersession preclude application of state workers\u2019 compensation laws to seamen). To apply the Illinois scheme of no-fault compensation in a field where Congress specifically provides certain other types of remedies would disrupt the uniform nature of only applying those remedies in that field. This we cannot do under Jensen or its progeny. See Jensen, 244 U.S. at 216, 61 L. Ed. at 1098, 37 S. Ct. at 529 (no state legislation can validly be applied \u201cif it contravenes the essential purpose expressed by an act of Congress *** or interferes with the proper harmony and uniformity of\u201d maritime law). Unless the Supreme Court creates a \u201ctwilight zone\u201d in the Jones Act context and further reforms the Jensen doctrine in this respect, the Court\u2019s current interpretation of the Constitution precludes us from applying state law in a field where Congress has acted. See Lindgren, 281 U.S. at 46, 74 L. Ed. at 692, 50 S. Ct. at 211; Benders, 636 A.2d at 1317; see 820 ILCS 305/1 (West 1998) (Illinois Workers\u2019 Compensation Act will not apply to employees where federal law provides exclusive remedies).\nClaimant nonetheless urges this court to follow two cases where the \u201ctwilight zone\u201d concept was applied to cover injured seamen under state workers\u2019 compensation acts. In Maryland Casualty Co. v. Toups, 172 F.2d 542 (5th Cir. 1949), the worker was both a captain and crew of a vessel that ferried pilots to seagoing vessels coming into and leaving Port Arthur, Texas. On the day the worker died, he was at work on a small dock making fenders for the boat he captained. Somehow, unknown to any witnesses, the worker fell off the dock and drowned. In finding concurrent jurisdiction, the court stated the following:\n\u201cThe deceased, under the holdings of the Supreme Court *** was, no doubt, a seaman on a vessel engaged in navigation and in aid of navigation, whose heirs, in the absence of an applicable State Workers\u2019] Compensation Act, would be remitted to the Jones Act for redress. But since an action under the Jones Act must be grounded upon negligence, and since in the present case no negligence of the employer can be shown, the heirs of the deceased would be without remedy under the Act or in admiralty. Such a result is not imperative unless the invocation of the State Compensation Act would \u2018interfere with the proper harmony or uniformity of that law [admiralty] in its international or interstate relations.\u2019 No inharmonious result is here possible. The deceased at the time of his death was working upon the dock making.fenders for the use of his small boat. He hauled no interstate or foreign commerce. Neither his vessel nor his work affected the intricate relations that involve the ship, crew, master, owner, cargo, shipper, consignee, or responsibility, or lack of it, under the law of the sea. Neither the activity of the deceased nor the method of compensation agreed upon for his family could have interfered with the proper harmony or the uniformity of the law that prevails, and should prevail, in all substantial relations arising out of maritime commerce, whether interstate or international.\u201d Toups, 172 F.2d at 546.\nSimilarly, the Appellate Court of Alabama found concurrent jurisdiction even though the worker was clearly a \u201cseaman.\u201d In Haire v. Devcon International Corp., 668 So. 2d 775 (Ala. Ct. App. 1995), claimant was captain of a dredge in Antigua, West Indies, and spent 50% of his time on the dredge and 50% on land. He injured himself when he slipped off a bulldozer located on land. Although the court believed that Congress preempted state workers\u2019 compensation remedies by enacting the Jones Act, it nevertheless followed Toups and applied the \u201ctwilight zone\u201d doctrine to entitle claimant to an action under the state\u2019s workers\u2019 compensation act. Haire, 668 So. 2d at 778-79.\nAs can be seen, these cases effectively ignore the case law and the concerns that we have discussed above. As such, we reject these cases as unpersuasive and maintain that claimant\u2019s seaman status limits his ability to recover for his injuries to the exclusive remedies provided by the Jones Act.\nIII. Conclusion\nFor the reasons discussed above, we affirm the circuit court\u2019s confirmation of the Commission\u2019s decision.\nAffirmed.\nMcCULLOUGH, P.J., and COLWELL, HOLDRIDGE, and RARICK, JJ., concur.\nThe Merchant Marine Act derived its more commonly known name from its sponsor, Wesley L. Jones. 2 M. Norris, The Law of Seamen \u00a7 30:3, at 328 n.22 (4th ed. 1985).\nConsequently, claimant\u2019s argument that the \u201csavings to suitors\u201d clause somehow supports concurrent jurisdiction is patently without merit, as it has twice been rejected by the Supreme Court.\nThis compensation act was substantially modeled after New York\u2019s workers\u2019 compensation act. G. Grant & C. Black, The Law of Admiralty \u00a7 6-46, at 408.\nAfter 1972, Congress extended the jurisdiction of the Longshoremen\u2019s Act landward beyond the shoreline. This was interpreted as expanding the sphere of concurrent jurisdiction into a sphere that had been viewed as the province of state workers\u2019 compensation law. See Sun Ship, Inc., 447 U.S. at 719-20. 65 L. Ed. 2d at 462-63. 100 S. Ct. at 2436.", "type": "majority", "author": "JUSTICE RAKOWSKI delivered the opinion of the court:" } ], "attorneys": [ "William G. Gillies, Jr., of McCarthy, Callas, Fuhr & Ellison, of Rock Island, for appellant.", "Jill A. Baker and Martin T. Spiegel, both of Debboli, Millman & Spiegel, of Chicago, for appellees." ], "corrections": "", "head_matter": "HASKELL GREEN, Appellant, v. THE INDUSTRIAL COMMISSION et al. (Schadler Enterprises et al., Appellees).\nThird District (Industrial Commission Division)\nNo. 3\u201498\u20140009WC\nOpinion filed August 17, 1999.\nRehearing denied October 13, 1999.\nWilliam G. Gillies, Jr., of McCarthy, Callas, Fuhr & Ellison, of Rock Island, for appellant.\nJill A. Baker and Martin T. Spiegel, both of Debboli, Millman & Spiegel, of Chicago, for appellees." }, "file_name": "0271-01", "first_page_order": 289, "last_page_order": 302 }