Strait v. Treasurer of Missouri

Summary

The Missouri Supreme Court held that the Labor and Industrial Relations Commission had authority to substitute the deceased employee’s dependent children as recipients of permanent total disability benefits. Because the employee died while the award remained pending on timely appeal, the court applied Schoemehl v. Treasurer of the State of Missouri and remanded for benefits to be paid to the children from the date of their mother’s death.

Holdings

1. When an employee receiving permanent total disability benefits dies from causes unrelated to the work injury while the claim remains pending because a timely appeal has been filed, the employee's right to compensation survives to the employee's dependents under Schoemehl, and the Commission may amend the award to substitute the dependents as recipients.
2. A judicial decision interpreting the workers' compensation statutes applies prospectively to actions pending on the date the decision issued; because Strait's claim was pending when Schoemehl was decided, Schoemehl applied.

Questions Presented

1. Whether the Labor and Industrial Relations Commission had authority to amend a permanent total disability award and substitute the deceased employee's dependent children as claimants when the employee died during the period in which the award remained pending on appeal.
2. Whether Schoemehl v. Treasurer of the State of Missouri applied to a workers' compensation claim that was pending when Schoemehl was decided.

Disposition

reversed_and_remanded