Prate Roofing and Installations, LLC v. Liberty Mutual Insurance Corp.

Summary

The Illinois Supreme Court held that the Department of Insurance had statutory authority under section 462 of the Illinois Insurance Code to resolve Prate's dispute over additional workers' compensation premiums. The dispute concerned Liberty's application of an assigned-risk rating rule, and resolving that issue could require factual determinations about subcontractor insurance, employees, and premium calculations. The court distinguished the prior decision involving a pure employment-status dispute, reversed the appellate court, and remanded for consideration of the remaining merits.