IICLE Flashpoint – July 2025

By Kisa P. Sthankiya

Strict Deadlines Limit Judicial Review: Circuit Court Lacked Jurisdiction in Singletary Due to Late Filing

In Singletary v. IWCC, 2025 IL App (1st) 240120WC, the First District Appellate Court affirmed the dismissal of a workers’ compensation appeal for want of jurisdiction, emphasizing the strict, jurisdictional nature of statutory deadlines for filing a circuit court review of a Commission decision.

Rashun Singleton filed two applications for adjustment of claim in 2016 and 2018, alleging a work-related injury from her employment with Amita Health/Advent Health. The cases were consolidated. In July 2019, both claims were dismissed for want of prosecution. Singleton filed multiple motions to reinstate, all of which were denied by the arbitrator. The Commission affirmed the arbitrator’s denial on January 31, 2023.

That same day, the Illinois Workers’ Compensation Commission sent notice of its decision to both parties via its CompFile system. Singleton, representing herself, did not file a petition for judicial review in the circuit court until March 1, 2023—well outside the 20-day statutory deadline.

Amita moved to dismiss the appeal for lack of subject-matter jurisdiction under section 2-619(a)(1) of the Illinois Code of Civil Procedure. The circuit court agreed and dismissed the petition. Singleton’s subsequent motions to vacate and reconsider were denied.

The issues before the Appellate Court included:

  • Whether the 20-day period to seek judicial review under section 19(f)(1) of the Workers’ Compensation Act began on January 31, 2023, when electronic notice was sent via CompFile;
  • Whether the method of notice (email) complied with the statutory requirement for notice; and
  • Whether Singleton’s late filing could be excused on equitable grounds.

The Appellate Court affirmed the circuit court’s dismissal for lack of jurisdiction. The Court held that:

  1. The 20-Day Filing Deadline Began When Notice Was Sent via CompFile.
    Under section 19(f)(1), judicial review must be initiated within 20 days of receiving notice of the Commission’s decision—not the decision itself. Here, notice was deemed received on January 31, 2023, when the CompFile system generated and sent emails to the parties. The court took judicial notice of these public records.
  2. Electronic Notice Is Valid When the Party Subscribes to CompFile.
    The court rejected Singleton’s argument that section 19(i) required personal or mailed notice. By registering with CompFile and consenting to electronic service, Singleton agreed to receive notice via email. Under 50 Ill. Adm. Code 9015.50(c), such service is deemed complete upon transmission.
  3. Late Filing Is Jurisdictional and Cannot Be Excused.
    The court reaffirmed that the statutory filing period is jurisdictional. Absent strict compliance, the circuit court lacks subject-matter jurisdiction. Singleton’s argument that the email may have gone to her spam folder was irrelevant under existing case law.

The Singletary decision is a reminder that while the Illinois Workers’ Compensation Commission may exercise discretion in certain procedural matters, the statutory deadlines for initiating judicial review in circuit court are strictly jurisdictional. The appellate court reinforced that:

  • Receipt of electronic notice via CompFile satisfies the statutory requirement for notice if the party has registered for the system.
  • The statutory 20-day window to seek circuit court review under 820 ILCS 305/19(f)(1) begins on the date notice was issued, not receipt of the decision or party’s actual knowledge.
  • Jurisdiction cannot be conferred by equitable arguments, such as misunderstanding or inadvertent delay.

Comparison to Ryba: Different Rules at Different Levels

We previously analyzed the Appellate Court’s decision in Ryba v. IWCC. In . In Ryba, the Appellate Court affirmed the Commission’s reinstatement of a claim, where the motion to reinstate was filed well after the 60-day period provision of the Workers Compensation Act.  

The Ryba and Singletary decisions present a clear contrast in how timing issues are treated, depending on whether the matter remains before the Commission or has moved into the judicial review phase.

In Ryba, the Appellate Court allowed reinstatement of a claim long after the 60-day reinstatement period had passed. The court emphasized that where factual disputes exist—such as denial of notice—the Commission retains discretion to resolve those facts and, where appropriate, toll deadlines. The decision acknowledged the Commission’s broader procedural discretion, particularly during unusual periods like the COVID-19 pandemic.

By contrast, Singletary confirms that once a case moves into the judicial review phase, the jurisdictional lines are strictly drawn. The 20-day filing period under section 19(f)(1) is not a discretionary deadline—it is a jurisdictional bar. Unlike in Ryba, factual disputes such as whether an email went to a spam folder are irrelevant if notice was properly issued and the statutory clock began.

The key distinction lies in statutory discretion vs. jurisdictional mandates:

  • The Commission has discretion to determine factual disputes regarding notice and may permit reinstatement based on equitable considerations (Ryba).
  • The circuit court’s jurisdiction under section 19(f)(1) is strictly limited by statute, and equitable considerations cannot extend the deadline (Singletary).

Practitioners must understand the procedural posture of a workers’ compensation case and the implications it has on applicable deadlines. Before the Commission, factual disputes over notice and good cause may allow some leeway. But once a decision is final and the case moves into judicial review, strict compliance with statutory deadlines is essential. Electronic notice is deemed sufficient, and failure to act within 20 days will likely prove fatal to the appeal, as it did in Singletary.