Sanz v. Douglas Collins Construction

¶ 1. Claimant Antonio Sanz appeals the Commissioner of Labor and Industry’s denial of his request for a lump sum payment of his permanent total disability (PTD) workers’ compensation benefits. The Commissioner concluded that a 2000 amendment to 21 V.S.A. § 652 allowing PTD benefits to be paid in a lump sum was a substantive change to the law that could not be given retroactive effect. Claimant argues that the Commissioner erred in not applying the statute as amended. We affirm.

¶ 2. The relevant facts of this case are not disputed. Claimant was seriously injured on January 30,1998, when, in…