West Bend Mutual Insurance Co. v. Trrs Corp.

Summary

The court held that the primary jurisdiction doctrine does not authorize a circuit court to stay a pending Illinois Workers’ Compensation Commission proceeding. Although the circuit court had concurrent jurisdiction over the insurance coverage dispute, the doctrine permits a court to stay its own proceedings to allow agency consideration of specialized issues, not to halt the agency’s proceeding. The appellate judgment reversing the stay was affirmed, and the cause was remanded so the circuit court could consider any alternative basis for a stay.