CANDICE MARTIN, Appellee, v. GOODRICH CORPORATION et al., Appellants., 2025 IL 130509

Summary

• •Section 1(f) of the Illinois Workers' Occupational Diseases Act is a statute of repose that bars compensation after a defined period of time, regardless of when the claim accrued or injury occurred.
• •The amendment adding Section 1.1 to the Workers' Occupational Diseases Act, which allows employees to bring civil actions if their claims are barred by a statute of repose, is a substantive change that applies prospectively under Section 4 of the Illinois Statute on Statutes.
• •Applying Section 1.1 prospectively to allow claims barred by the statute of repose in Section 1(f) does not violate due process under the Illinois Constitution because employers do not have a vested right in the exclusivity defense until the employee's cause of action accrues.

• •Rodney Martin worked for B.F. Goodrich Company from 1966 to 2012 and was exposed to vinyl chloride monomer until 1974, which allegedly caused him to develop angiosarcoma of the liver. He was diagnosed in 2019 and ...