Supreme Court of Missouri / May 22, 2018
Andrew Dickemann, Appellant, vs. Costco Wholesale Corporation, Respondent.
Andrew Dickemann, who was receiving permanent total disability benefits for a work-related injury, and his employer, Costco, agreed to commute his weekly payments to a lump sum. They sought approval from the Labor and Industrial Relations Commission, which declined on the grounds that it lacked authority to approve it as a settlement or a commutation. The Missouri Supreme Court affirmed the Commission's decision, holding that a post-award agreement to commute benefits is not a "claim" for settlement purposes under section 287.390 and that the proposed lump sum failed to meet the financial equivalency requirements for a commutation under section 287.530.