Gaffney v. ORLAND FIRE PROTECTION DIST.
360 Ill. Dec. 549
| Ill. | 2012Background
- Gaffney and Lemmenes, Illinois firefighters, sought health insurance benefits under 820 ILCS 320/10 after line-of-duty injuries.
- Gaffney was denied benefits; Lemmenes sought declaratory relief; appellate court rulings differed on eligibility and review mechanics.
- The Illinois Supreme Court consolidated the appeals and reversed the appellate court judgments in both cases.
- Gaffney asserted the district had no authority to decide section 10 eligibility and that declaratory relief was proper.
- Lemmenes contended his injury occurred during an emergency training exercise, entitling him to benefits under §10(b).
- The court analyzed whether §10(b)'s ‘emergency’ requirement could be satisfied in training-exercise contexts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether declaratory judgment was proper | Gaffney argues declaratory relief is appropriate to interpret §10. | Defendants contend review should be via administrative review/ certiorari, not declaratory judgment. | Declaratory judgment proper; board’s action not subject to ARL review. |
| Whether §10(b) emergency applies to training | Gaffney contends training emergencies fall within §10(b)'s emergency trigger. | Defendants contend training lacks true emergency or imminent danger; not §10(b) eligible. | Gaffney entitled to §10 benefits; emergency may arise during training if unforeseen and urgent. |
| Whether Lemmenes satisfied §10(b) | Lemmenes argues training exercise created an emergency requiring urgent response. | Exercise was controlled; no unforeseen imminent danger; not §10(b) emergency. | Lemmenes not entitled to §10 benefits; appellate decision reversed. |
| Whether the Fire Protection District Act creates an administrative remedy | Gaffney contends §10 benefits are not governed by district’s administrative process. | District’s procedures resemble an administrative decision review. | District did not create an ARL-reviewable administrative decision on §10 eligibility. |
| Scope of §10(a) vs §10(b) alignment with legislative intent | Gaffney urges liberal construction to fulfill purpose of benefits for line-of-duty injuries. | statutory text plainly limits benefits; training-based injuries not §10(b) emergencies. | Court adopts §10(b) interpretation allowing some training-derived emergencies to qualify; Lemmenes denied. |
Key Cases Cited
- DeRose v. City of Highland Park, 386 Ill.App.3d 658 (2008) (defined emergency in §10(b) as urgent, immediate action)
- Krohe v. City of Bloomington, 204 Ill.2d 392 (2003) (catastrophic injury equates to line-of-duty disability)
- People v. Davison, 233 Ill.2d 30 (2009) (dictionary usage to determine undefined statutory terms)