1st Dist. Appellate Court – Decided 2/20/25
Public Safety Officers Benefit Act Case
The Plaintiff, Charles R. Ford, a firefighter/paramedic for the Village of Northbrook, suffered a catastrophic shoulder injury while transferring a patient at the hospital. He was granted a line-of-duty disability pension but was denied health insurance benefits under the Public Safety Employee Benefits Act (the Act) by the Village, which argued that his injury did not occur during a response to an emergency.
Ford sought judicial review, and the Circuit Court reversed the Village’s decision, finding that he was injured while responding to what he reasonably believed to be an emergency. The Village appealed the Circuit Court decision that reversed its denial of benefits to Ford under the Act. The Village argued that Ford was not injured during an objectively defined emergency, that the emergency had ceased before Ford was injured, and that his subjective belief was insufficient to meet the legal standard.
The Appellate Court found Ford suffered a catastrophic injury under section 10(a), the dispute was whether he met the emergency requirement under section 10(b). Citing prior cases, the court analyzed whether unforeseen circumstances involving imminent danger were present. It distinguished Ford’s situation from Wilczak, where a firefighter assisted a disabled person without life-threatening conditions, and found it more similar to Springborn, where officers responded to urgent roadway hazards. Ford responded to a priority 1 emergency, observed a weak patient in distress, and was injured during the hospital transfer. Given the lack of a prior diagnosis and the need for immediate care, the court found his belief in the emergency reasonable.
The Circuit Court’s reversal was affirmed, entitling Ford to benefits under the Act.