A recent 1st District Appellate Court Rule 23 order brought to light an issue of first impression in Illinois as to whether an onsite employee of an independent contractor constitutes a “third person” under Section 411 of the Restatement (Second) of Torts and thus is entitled to advance negligent hiring claims against a general contractor or owner. Carney v. Union Pacific Railroad, 2014 IL App (1st) 130105-U.Most injured employees first turn to Section 414 of the Restatement (Second) of Torts to pursue a third …