The Village of Vernon Hills v. Heelan
2015 IL 118170
| Ill. | 2015Background
- In December 2009 Vernon Hills officer William Heelan slipped on ice while responding to an emergency, later undergoing right and then left hip replacements and leaving police service.
- The Vernon Hills Police Pension Fund Board awarded Heelan a line-of-duty disability pension under 40 ILCS 5/3-114.1 after hearings that included physician reports and testimony; the Village did not intervene in that pension proceeding.
- Heelan sought continued employer-paid health insurance under the Public Safety Employee Benefits Act (820 ILCS 320/10), claiming a “catastrophic injury.”
- The Village sued for declaratory relief, arguing Heelan did not meet section 10(a)’s “catastrophic injury” requirement and disputed causation; it conceded section 10(b) (response to a perceived emergency).
- Lower courts struck discovery on catastrophic-injury issues, granted directed finding for Heelan, and held that an award of a line-of-duty disability pension establishes a “catastrophic injury” under section 10(a) as a matter of law.
- The Illinois Supreme Court affirmed, rejecting the Village’s statutory-construction and procedural due-process challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “catastrophic injury” under 820 ILCS 320/10(a) | Krohe does not make pension-award dispositive; Village argues line-of-duty pension should not automatically satisfy section 10(a) | Heelan: Krohe and later cases define catastrophic injury as an injury resulting in a line-of-duty disability pension | An award of a line-of-duty disability pension establishes a catastrophic injury as a matter of law; court affirms Krohe/Nowak precedent |
| Whether Village could litigate nature, extent, causation after pension award | Village: pension proceedings differ and did not adjudicate catastrophic-injury elements; discovery and litigation should be allowed | Heelan: pension award resolves section 10(a); no need for further litigation on that element | Where a line-of-duty pension award is uncontroverted, section 10(a) is satisfied and further discovery on catastrophic injury is unnecessary |
| Procedural due process challenge to preclusion of discovery/hearing | Village: denial of opportunity to litigate deprived it of due process | Heelan: no disputed facts remain on catastrophic injury; statutory enactment and existing procedures provide sufficient process; Village could have intervened in pension proceeding | No due process violation; statutory definition and the pension award leave no relevant factual dispute, and the legislative enactment provides the required process |
| Collateral estoppel / estoppel to litigate pension-related facts | Village claimed it was collaterally estopped from litigating catastrophic-injury issue | Heelan: court relied on statutory construction rather than collateral estoppel; pension award establishes the element | Court rejects collateral-estoppel framing; outcome rests on statutory construction that pension award conclusively establishes catastrophic injury |
Key Cases Cited
- Krohe v. City of Bloomington, 204 Ill. 2d 392 (Ill. 2003) (construing “catastrophic injury” as synonymous with injury resulting in a line-of-duty disability pension)
- Nowak v. City of Country Club Hills, 2011 IL 111838 (Ill. 2011) (reaffirming that a line-of-duty pension award fixes the date an employer’s duty to pay health insurance premiums attaches)
- Gaffney v. Board of Trustees of the Orland Fire Protection District, 2012 IL 110012 (Ill. 2012) (treating a line-of-duty pension award as establishing catastrophic injury under section 10(a))
- Richter v. Village of Oak Brook, 2011 IL App (2d) 100114 (Ill. App. Ct. 2011) (noting that a pension board award establishes catastrophic injury for section 10(a) purposes)