{
  "id": 4291882,
  "name": "SECURITAS, INC., Appellant, v. ILLINOIS WORKERS' COMPENSATION COMMISSION et al. (Wayne O'Connor, Appellee)",
  "name_abbreviation": "Securitas, Inc. v. Illinois Workers' Compensation Commission",
  "decision_date": "2009-11-23",
  "docket_number": "No. 5\u201409\u20140184WC",
  "first_page": "1103",
  "last_page": "1104",
  "citations": [
    {
      "type": "official",
      "cite": "395 Ill. App. 3d 1103"
    }
  ],
  "court": {
    "name_abbreviation": "Ill. App. Ct.",
    "id": 8837,
    "name": "Illinois Appellate Court"
  },
  "jurisdiction": {
    "id": 29,
    "name_long": "Illinois",
    "name": "Ill."
  },
  "cites_to": [
    {
      "cite": "377 Ill. App. 3d 499",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        4274321
      ],
      "year": 2007,
      "pin_cites": [
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          "page": "505"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/377/0499-01"
      ]
    },
    {
      "cite": "294 Ill. App. 3d 685",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        35450
      ],
      "year": 1998,
      "pin_cites": [
        {
          "page": "688"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/294/0685-01"
      ]
    },
    {
      "cite": "345 Ill. App. 3d 716",
      "category": "reporters:state",
      "reporter": "Ill. App. 3d",
      "case_ids": [
        5873122
      ],
      "year": 2003,
      "pin_cites": [
        {
          "page": "719"
        }
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-app-3d/345/0716-01"
      ]
    }
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  "analysis": {
    "cardinality": 261,
    "char_count": 3120,
    "ocr_confidence": 0.775,
    "pagerank": {
      "raw": 4.03580807328026e-08,
      "percentile": 0.14434567420726074
    },
    "sha256": "4ec84553c019640923915972a18d7d035267e882d03f14db6699340945c5d4b2",
    "simhash": "1:15c61806e1f34ce3",
    "word_count": 496
  },
  "last_updated": "2023-07-14T16:58:02.073967+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
  },
  "casebody": {
    "judges": [],
    "parties": [
      "SECURITAS, INC., Appellant, v. ILLINOIS WORKERS\u2019 COMPENSATION COMMISSION et al. (Wayne O\u2019Connor, Appellee)."
    ],
    "opinions": [
      {
        "text": "JUSTICE HUDSON\ndelivered the opinion of the court:\nClaimant, Wayne O\u2019Connor, filed an application for adjustment of claim pursuant to the Workers\u2019 Compensation Act (820 ILCS 305/1 et seq. (West 2006)). In it, he alleged that he sustained a work-related injury when he fell while walking down a flight of stairs during his employment with Securitas, Inc. (respondent). The arbitrator agreed and awarded claimant 142A weeks of temporary total disability (TTD) at $291.01 per week and 2 weeks of TTD at $159.91 per week (820 ILCS 305/8(b) (West 2006)) as well as $5,792.28 for medical expenses (820 ILCS 305/8(a) (West 2006)). The Workers\u2019 Compensation Commission (Commission) affirmed, adopting the decision of the arbitrator in full. The circuit court confirmed the Commission\u2019s decision. Respondent now appeals, contesting the Commission\u2019s findings regarding causation and claimant\u2019s average weekly wage. However, we are unable to address these issues as we lack jurisdiction over this appeal. Accordingly, we dismiss it.\nClaimant contends that the bond submitted by respondent is insufficient to vest this court with jurisdiction over this matter. We agree. Filing a proper bond is a jurisdictional prerequisite to judicial review in a matter emanating from the Commission. Freedom Graphic Systems, Inc. v. Industrial Comm\u2019n, 345 Ill. App. 3d 716, 719 (2003). Claimant notes two alleged defects. First, the person who signed the bond is not identified on the face of the bond as an officer of respondent. In First Chicago v. Industrial Comm\u2019n, 294 Ill. App. 3d 685, 688 (1998), this court rejected such a requirement, holding that the party signing the bond need not identify himself or herself on the face of the bond as an officer of the corporation in order to invoke the subject matter jurisdiction of the court. The second defect claimant points to is that the Commission fixed the amount of the bond as $10,100 and the bond filed by respondent is limited to $10,000. In Residential Carpentry, Inc. v. Kennedy, 377 Ill. App. 3d 499, 505 (2007), we noted that substantial compliance with the bond requirement has been held acceptable with regard to \u201cirregularities in form.\u201d The amount of the bond, however, is a matter of substance rather than form. Respondent points to no authority suggesting that a de minimis error in the amount of a bond could be excused (indeed, respondent has not filed a reply brief at all). Accordingly, we perceive no basis to excuse respondent\u2019s failure to post a bond for the full amount set by the Commission. We therefore dismiss this appeal.\nAppeal dismissed.\nMcCullough, p.j., and HOFFMAN, HOLDRIDGE, and DONOVAN, JJ., concur.",
        "type": "majority",
        "author": "JUSTICE HUDSON"
      }
    ],
    "attorneys": [
      "Robert A. Hoffman, of Brady, Connolly & Masuda, P.C., of Normal, for appellant.",
      "Colleen Joern Vetter and Clare R. Behrle, both of Schuchat, Cook & Werner, of St. Louis, Missouri, for appellee."
    ],
    "corrections": "",
    "head_matter": "SECURITAS, INC., Appellant, v. ILLINOIS WORKERS\u2019 COMPENSATION COMMISSION et al. (Wayne O\u2019Connor, Appellee).\nFifth District (Illinois Workers\u2019 Compensation Commission Division)\nNo. 5\u201409\u20140184WC\nOpinion filed November 23, 2009.\nRehearing denied December 23, 2009.\nRobert A. Hoffman, of Brady, Connolly & Masuda, P.C., of Normal, for appellant.\nColleen Joern Vetter and Clare R. Behrle, both of Schuchat, Cook & Werner, of St. Louis, Missouri, for appellee."
  },
  "file_name": "1103-01",
  "first_page_order": 1119,
  "last_page_order": 1120
}