The Third Dist. IL Appellate court decision, Armstead v. National Freight, Inc. (2020 IL App (3d) 170777), may have significant ramifications for Workers’ Compensation (WC)practitioners (and Pro Se claimants) because the court held that Plaintiff’s personal injury (3rd party) claim was barred by collateral estoppel based on the description of the injuries in the Pennsylvania WC settlement contract.

Here, the Plaintiff agreed that his injury was a “right knee strain” and did not list all other claimed injuries that he may claim in the Personal Injury case. To my ...