In Berghoff v. R.J. Frisby Manufacturing, 720 F. Supp. 649, 651 (N.D. Ill., 1989) a federal court had to decide whether section 13-205 or 13-202 of the Civil Code should apply to a retaliatory discharge claim brought under the Workman's Compensation Act. Significantly, the Berghoff Court found that Section 13-202 was limited, in relevant part, to actions for "an injury to the person." Thus, the Court reasoned, the retaliatory discharge claim would fall under the five-year "catch all" provision of Section 13-205. While the Berghoff Court did go on to say that the retaliatory discharge claim was one that "arose out of a contractual relationship," it did not go so far as to say that it arose out of a contract.