Municipality brought action against police officer seeking declaratory judgment that municipality was not obligated, under the Public Safety Employee Benefits Act (Act), to pay health insurance premiums for officer and his family after officer was awarded a line-of-duty disability pension by the board of trustees for the municipality’s police pension fund.
The Circuit Court, Lake County, Margaret entered judgment in favor of officer but denied his motion for sanctions. Municipality appealed and officer cross-appealed. The Appellate Court affirmed. Municipality petitioned for leave to appeal.
The Supreme Court of Illinois held that:
- Where it is uncontroverted that a line-of-duty disability pension has been awarded to a police officer pursuant to the Pension Code, section of Act providing for health insurance benefits upon a “catastrophic injury” is satisfied as a matter of law, and
- Construction of Act as such did not deny due process to municipality.
Where it is uncontroverted that a line-of-duty disability pension has been awarded to a police officer pursuant to the Pension Code, section of the Public Safety Employee Benefits Act (Act) providing for health insurance benefits upon a “catastrophic injury” is satisfied as a matter of law, and there is no need to engage in discovery or present evidence regarding the officer’s injury in order to recover benefits under the Act.
Construction of Public Safety Employee Benefits Act (Act) to provide that where it is uncontroverted that a line-of-duty disability pension has been awarded to a police officer pursuant to the Pension Code, section of Act providing for health insurance benefits upon a “catastrophic injury” is satisfied as a matter of law, did not deny due process to municipality, despite argument that construction of statute denied municipality opportunity to litigate nature of officer’s injuries, in municipality’s action seeking declaration that it was not obligated to pay health insurance premiums for officer and his family after officer was awarded line-of-duty disability pension. Enactment of Act itself afforded municipality all of the process that it was due.