Arizona Revised Statutes

Ariz. Rev. Stat. § 23-1067 (2026)

Commutation of compensation to lump sum payment

✓ current as of May 2026
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A. The commission may allow commutation of the compensation awarded pursuant to section 23-1044, subsection B to a lump sum payment of not to exceed twenty-five thousand dollars, with or without the consent of the carrier liable for the commutation, under such rules, regulations and system of computation as it devises for obtaining the present value of the compensation.

B. The commission may allow commutation of compensation pursuant to section 23-1044, subsection C, and section 23-1045, subsections B, C and D, to a lump sum of not to exceed twenty-five thousand dollars for commutation requests made before July 1, 1987, fifty thousand dollars for commutation requests made from and after June 30, 1987 but before July 1, 2007 and one hundred fifty thousand dollars for commutation requests made from and after June 30, 2007, with the consent of the carrier liable to pay the claim, under such rules, regulations and system of computation as it devises for obtaining the present value of the compensation.

 

Notes of Decisions
Cited in 22 cases, 1970–1999 · leading case: Kessen v. Stewart, 990 P.2d 689 (Ariz. Ct. App. 1999).
Kessen v. Stewart, 990 P.2d 689 (Ariz. Ct. App. 1999). · cites it 14× “AR.S. § 23-1067(B) (emphasis added). ¶ 5 The Kessens assert that section 23-1067(B) requires the consent even of an uninsured employer before the ICA may approve a request for a lump-sum commutation because, by statute, an uninsured employer is liable to reimburse the Special…”
In Re the Marriage of Cupp, 730 P.2d 870 (Ariz. Ct. App. 1986). · cites it 6× “There are no Arizona cases which discuss the effect to be given a lump sum workers’ compensation payment made during the marriage. The Industrial Commission has the authority to commute workers’ compensation benefits to a lump sum payment, not in excess of $25,000, when it…”
Scowden v. Indus. Comm'n, 563 P.2d 336 (Ariz. Ct. App. 1977). · cites it 12× “All parties agree the petitioner met the requirements of ARS § 23-1067. After formal hearing the Commission disapproved of the petition and this appeal followed.”
Prigosin v. Indus. Comm'n, 546 P.2d 823 (Ariz. 1976). · cites it 4× “A.R.S. § 23-1067, the statute authorizing lump-sum payments, reads: “A.”
Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 219 (Ariz. 1986). · cites it 3× “After a final award is made, A.R.S. § 23-1067 governs all lump-sum commutations of the award,”
Time, D.C. Freight Lines v. Indus. Comm'n, 713 P.2d 318 (Ariz. Ct. App. 1985). · cites it 4× “In rejecting these arguments, the Cunningham court generally observed: In discussing A.R.S. § 23-1067 (1956) these general principles must be kept in mind.”
Jones v. Indus. Com'n of Arizona, 562 P.2d 1104 (Ariz. Ct. App. 1977). · cites it 4× “This review questions the denial by the Industrial Commission (Commission) of a petition for commutation of compensation to lump sum award authorized by A.R.S. § 23-1067. Review of a denial of such an award would, under ordinary circumstances, be limited to a determination of…”
Employers Mut. Liab. Ins. Co. of Wisconsin v. Indus. Comm'n, 592 P.2d 392 (Ariz. Ct. App. 1979). · cites it 4× “The Commission’s second proposition is that, assuming a genuine dispute over compensability, it is without jurisdiction to approve the compromise and settlement proposed in this case because the amount exceeds $25,000 which is the maximum lump sum commutation award authorized by…”
Safeway Stores, Inc. v. Indus. Comm'n, 730 P.2d 214 (Ariz. Ct. App. 1985). · cites it 6× “§ 23-906 provides that an employee is generally deemed to have accepted workers’ compensation unless, prior to sustaining injury, the employee rejects the provisions of the workers’ compensation law by signed and dated written notice delivered to the employer before the injury.”
Holsum Bakery v. Indus. Comm'n, 955 P.2d 11 (Ariz. Ct. App. 1997). · cites it 3× “By contrast, settlements are governed by case law, but as noted, prior cases have not specifically addressed whether settlements may affect future medical benefits.”
Travelers Ins. Co. v. Indus. Comm'n, 518 P.2d 1015 (Ariz. Ct. App. 1974). · cites it 4× “This case is important beyond the disputed money since it challenges the basic concept that the Industrial Commission shall control the proceedings under the Arizona Workmen’s Compensation Act.”
Gray v. Indus. Comm'n, 539 P.2d 973 (Ariz. Ct. App. 1975). · cites it 2× “§ 23-107A(3) authorizing the Commission to: “3. Promote the voluntary arbitration, mediation and conciliation of disputes between employers and employees.”
— Ariz. Rev. Stat. § 23-1067(A) — 1 case
Kar Prods., Inc. v. Indus. Comm'n, 678 P.2d 500 (Ariz. Ct. App. 1983).
— Ariz. Rev. Stat. § 23-1067(B) — 4 cases
Kessen v. Stewart, 990 P.2d 689 (Ariz. Ct. App. 1999). “AR.S. § 23-1067(B) (emphasis added). ¶ 5 The Kessens assert that section 23-1067(B) requires the consent even of an uninsured employer before the ICA may approve a request for a lump-sum commutation because, by statute, an uninsured employer is liable to reimburse the Special…”
Time, D.C. Freight Lines v. Indus. Comm'n, 713 P.2d 318 (Ariz. Ct. App. 1985). “In rejecting these arguments, the Cunningham court generally observed: In discussing A.R.S. § 23-1067 (1956) these general principles must be kept in mind.”
Stell v. Indus. Comm'n, 531 P.2d 543 (Ariz. Ct. App. 1975).
Jones v. Arizona-Colorado Land, 526 P.2d 712 (Ariz. 1974).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.