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Strict Deadlines Limit Judicial Review: Circuit Court Lacked Jurisdiction Due to Late Filing
In Singleton v. Illinois Workers’ Compensation Commission, 2025 IL App (1st) 240120WC-U, the First District Appellate Court affirmed the dismissal of a workers’ compensation appeal for want of jurisdiction, emphasizing the strict, jurisdictional nature of statutory deadlines for filing a circuit court review of a Commission decision.
Rashun Singleton filed two applications for adjustment of a claim in 2016 and 2018, alleging a work-related injury from Singleton’s employment with Amita Health/Advent Health. The cases were consolidated. In July 2019, both claims were dismissed for want of prosecution. Singleton filed multiple motions to reinstate, all of which were denied by the arbitrator. The Commission affirmed the arbitrator’s denial on January 31, 2023. 2025 IL App (1st) 240120WC-U at ¶¶5 – 6.
That same day, the Illinois Workers’ Compensation Commission sent notice of its decision to both parties via its CompFile system. Singleton, representing herself, did not file a petition for judicial review in the circuit court until March 1, 2023 — well outside the 20-day statutory deadline.
Amita moved to dismiss the appeal for lack of subject-matter jurisdiction under §2-619(a)(1) of the Illinois Code of Civil Procedure, 735 ILCS 5/2-619(a)(1). The circuit court agreed and dismissed the petition. Singleton’s subsequent motions to vacate and reconsider were denied.
The issues before the appellate court included the following:
1. whether the 20-day period to seek judicial review under §19(f)(1) of the Workers’ Compensation Act, 820 ILCS 305/1, et seq., began on January 31, 2023, when electronic notice was sent via CompFile;
2. whether the method of notice (email) complied with the statutory requirement for notice; and
3. whether Singleton’s late filing could be excused on equitable grounds.
The appellate court affirmed the circuit court’s dismissal for lack of jurisdiction. The court held:
- The 20-day filing deadline began when notice was sent via CompFile. Under §19(f)(1) of the Illinois Code of Civil Procedure, judicial review must be initiated within 20 days of receiving notice of the Commission’s decision — not the decision itself. Here, notice was deemed received on January 31, 2023, when the CompFile system generated and sent emails to the parties. The court took judicial notice of these public records.
- Electronic notice is valid when the party subscribes to CompFile. The court rejected Singleton’s argument that §19(i) of the Workers’ Compensation Act required personal or mailed notice. By registering with CompFile and consenting to electronic service, Singleton agreed to receive notice via email. Under 50 Ill.Admin. Code §9015.50(c), such service is deemed complete upon transmission.
- Late filing is jurisdictional and cannot be excused. The court reaffirmed that the statutory filing period is jurisdictional. Absent strict compliance, the circuit court lacks subject-matter jurisdiction. Singleton’s argument that the email may have gone to Singleton’s spam folder was irrelevant under existing caselaw. 2025 IL App (1st) 240120WC-U at ¶17.
The Singleton decision is a reminder that while the Illinois Workers’ Compensation Commission may exercise discretion in certain procedural matters, the statutory deadlines for initiating judicial review in circuit court are strictly jurisdictional. The appellate court reinforced the following:
1. Receipt of electronic notice via CompFile satisfies the statutory requirement for notice if the party has registered for the system.
2. The statutory 20-day window to seek circuit court review under 820 ILCS 305/19(f)(1) begins on the date notice was issued, not on the date of receipt of the decision itself or a party’s actual knowledge.
3. Jurisdiction cannot be conferred by equitable arguments, such as misunderstanding or inadvertent delay.
Comparison to Ryba: Different Rules at Different Levels
In May’s FLASHPOINTS, we analyzed the appellate court’s decision in Ryba v. Illinois Workers’ Compensation Commission, 2025 IL App (2d) 230596WC-U. In Ryba, the appellate court affirmed the Commission’s reinstatement of a claim when the motion to reinstate was filed well after the 60-day period provision of the Workers’ Compensation Act.
The Ryba and Singleton decisions present a clear contrast in how timing issues are treated, depending on whether the matter remains before the Commission or has moved into the judicial review phase.
In Ryba, the appellate court allowed reinstatement of a claim long after the 60-day reinstatement period had passed. The court emphasized that when factual disputes exist — such as denial of notice — the Commission retains discretion to resolve those facts and, when appropriate, toll deadlines. The decision acknowledged the Commission’s broader procedural discretion, particularly during unusual periods like the COVID-19 pandemic.
By contrast, Singleton confirms that once a case moves into the judicial review phase, the jurisdictional lines are strictly drawn. The 20-day filing period under §19(f)(1) of the Workers’ Compensation Act is not a discretionary deadline — it is a jurisdictional bar. Unlike in Ryba, factual disputes such as whether an email went to a spam folder are irrelevant if notice was properly issued and the statutory clock began.
The key distinction lies in statutory discretion vs. jurisdictional mandates:
1. The Commission has discretion to determine factual disputes regarding notice and may permit reinstatement based on equitable considerations (Ryba).
2. The circuit court’s jurisdiction under §19(f)(1) is strictly limited by statute, and equitable considerations cannot extend the deadline (Singleton).
Practitioners must understand the procedural posture of a workers’ compensation case and the implications it has on applicable deadlines. Before the Commission, factual disputes over notice and good cause may allow some leeway. But once a decision is final and the case moves into judicial review, strict compliance with statutory deadlines is essential. Electronic notice is deemed sufficient, and failure to act within 20 days will likely prove fatal to the appeal, as it did in Singleton.
For more information about workers’ compensation, see WORKERS’ COMPENSATION PRACTICE (IICLE®, 2023). Online Library subscribers can view it for free by clicking here. If you don’t currently subscribe to the Online Library, visitwww.iicle.com/subscriptions.