Armstead v. National Freight, Inc., 2020 IL App (3d) 170777

Plaintiff, while driving semi for his employer, a Pennsylvania corporation, was injured when a driver for another company, National Freight, struck Plaintiff's semi in Illinois. Plaintiff settled a workers’ compensation claim in Pennsylvania and then filed suit against Defendants in Illinois. The circuit court entered partial summary judgment for Defendants on the basis that the extent of Plaintiff’s injury was limited by a judicial admission in the workers’ compensation case. On rehearing, the Appellate Court affirmed partial summary judgment on the basis of collateral estoppel. All three elements of collateral estoppel were satisfied: (1) the issue decided in the workers’ compensation case was identical with the one presented in the Illinois claim, (2) there was a final judgment on the merits in the workers’ compensation case and (3) Plaintiff was a party to the prior adjudication. Plaintiff had both the incentive and opportunity to litigate the full extent of his injuries in the Pennsylvania workers' compensation proceedings.