Wilson v. Jim Snyder Drilling

LOHR, Justice.

In Wilson v. Jim Snyder Drilling, 729 P.2d 1022 (Colo.App.1986), the Colorado Court of Appeals held that cost-of-living increases in federal social security death benefits are not “periodic death benefits” within the meaning of section 8-50-103, 3B C.R.S. (1986), and therefore cannot be deducted from state workers’ compensation death benefits. In reaching that result, the court of appeals relied upon Engelbrecht v. Hartford Accident & Indemnity Co., 680 P.2d 231 (Colo.1984), in which we reached a like conclusion as to periodic disability ben efits payable under section…