Kordas v. Bob’s All Bright Electric, Inc., 2025 IL App (3d) 240482.

On Oct. 8, 2025, the Third District of the Illinois Appellate Court held that the Workers’ Compensation Act’s exclusive-remedy provision barred an employee’s negligence and intentional-misconduct claims against his employer after a coworker struck him in the head with a shovel during a psychotic episode.

In 2020, Kamil Kordas, a 12-year employee of Bob’s All Bright Electric, was struck in the head by a shovel wielded by Thomas Clarizio, the son of the firm’s owner. Clarizio was allegedly experiencing a psychotic episode caused by bipolar disorder at the time. Kordas sued the company for negligent hiring and supervision, and for civil battery. All Bright argued that Kordas’s claims were barred under the exclusive-remedy provision of the Act. The trial court granted summary judgment in favor of All Bright, and Kordas appealed.

The Third District affirmed. Kordas’s injury was “accidental” from the employer’s stand point as there was no evidence the company committed or expressly authorized an assault. Also, knowledge of mental-health treatment and tiredness at work did not amount to an intentional tort or fraudulent concealment. The attack also “arose out of” employment: The men had no social relationship, their disputes were work related, and Thomas testified the assault was not about Kordas personally. Finally, the claim was compensable under the Act even though Kordas did not file; therefore, he was not denied a worker’s compensation claim and the trial court did not err in its application of the exclusive-remedy provision.