On January 24, 2025, the Martin v. Goodrich Corp. decision marked a pivotal shift in Illinois occupational disease law. In a closely watched ruling, the Illinois Supreme Court upheld the constitutionality of a 2019 amendment to the Workers’ Occupational Diseases Act—fundamentally altering the balance between employers and workers suffering from latent industrial diseases.
At the heart of the case was a longstanding legal barrier: the Act’s 25-year statute of repose. For decades, this provision effectively shielded employers from liability when diseases such as mesothelioma or occupational cancers manifested decades after exposure. Under prior law, even workers with undeniable workplace exposure could be left without any remedy if their illness appeared too late.
That harsh result was cemented in the Illinois Supreme Court’s earlier decision in Folta v. Ferro Engineering, where the court held that employees were barred from suing their employers—even when workers’ compensation offered no recovery due to expired time limits. The outcome created a legal dead end: no compensation under the Act, and no ability to pursue a civil lawsuit.
The Illinois legislature responded in 2019 by adding Section 1.1 to the Act. This amendment carved out an exception to the statute’s exclusivity provisions, allowing employees to bring civil claims when their occupational disease is barred by the statute of repose.
In Martin, the Illinois Supreme Court confirmed that this legislative fix is both valid and enforceable. The court held that:
- The 25-year limit in Section 1(f) functions as a statute of repose.
- Section 1.1 applies to claims where compensation is barred due to that repose period.
- Employees whose diseases manifest after the repose period may pursue civil lawsuits against their employers.
Equally significant, the court rejected constitutional challenges from employers. It concluded that allowing these claims does not violate due process because employers do not possess a vested right to immunity under the Act’s exclusivity provisions.
The practical impact of Martin cannot be overstated. The decision reopens potential liability for employers in cases involving long-latency diseases—particularly asbestos-related conditions like mesothelioma, which often develop 20, 30, or even 40 years after exposure. Workers who were once barred from any recovery now have a viable path to seek justice through the civil court system.
In doing so, the court aligned Illinois law with a fundamental principle of fairness: that the passage of time alone should not extinguish accountability where the harm itself could not have been discovered earlier. The ruling ensures that the legal system recognizes the unique realities of occupational diseases—especially those rooted in decades-old industrial exposures.
For Illinois workers and their families, Martin v. Goodrich Corp. represents more than a statutory interpretation. It is a long-overdue correction—one that restores access to the courts for those whose injuries were delayed, but no less real.
This long-overdue pathway recognized in Martin v. Goodrich Corp. enables our firm to aggressively pursue civil accountability against employers who exposed their workforce to the hidden dangers of asbestos, ensuring that even decades-latent injuries are met with the justice those workers and their families deserve.