Indiana Code

Ind. Code § 22-3-2-15 (2026)

Employers not relieved of obligations by contracts, agreements, or rules; voluntary agreements; minors; approval; effect; payment of compensation; civil penalty

✓ current as of May 2026
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     Sec. 15. (a) No contract, agreement (written or implied), rule, or other device shall, in any manner, operate to relieve any employer in whole or in part of any obligation created by IC 22-3-2 through IC 22-3-6. However, nothing in IC 22-3-2 through IC 22-3-6 shall be construed as preventing the parties to claims under IC 22-3-2 through IC 22-3-6 from entering into voluntary agreements in settlement thereof, but no agreement by an employee or his dependents to waive his rights under IC 22-3-2 through IC 22-3-6 shall be valid nor shall any agreement of settlement or compromise of any dispute or claim for compensation under IC 22-3-2 through IC 22-3-6 be valid until approved by a member of the board, nor shall a member of the worker's compensation board approve any settlement which is not in accordance with the rights of the parties as given in IC 22-3-2 through IC 22-3-6. No such agreement shall be valid unless made after seven (7) days from the date of the injury or death.

     (b) A compromise settlement approved by a member of the worker's compensation board during the employee's lifetime shall extinguish and bar all claims for compensation for the employee's death if the settlement compromises a dispute on any question or issue other than the extent of disability or the rate of compensation.

     (c) A minor dependent, by parent or legal guardian, may compromise disputes and may enter into a compromise settlement agreement, and upon approval by a member of the worker's compensation board, the settlement agreement shall have the same force and effect as though the minor had been an adult. The payment of compensation by the employer in accordance with the settlement agreement shall discharge the employer from all further obligation.

     (d) Payment of compensation under an agreement authorized by this section must be made not later than thirty (30) days after the date the worker's compensation board approves the agreement. An employer that fails to comply with this subsection is subject to a civil penalty under IC 22-3-4-15.

Formerly: Acts 1929, c.172, s.15; Acts 1943, c.136, s.1; Acts 1945, c.284, s.1; Acts 1974, P.L.108, SEC.6. As amended by P.L.28-1988, SEC.25; P.L.1-1991, SEC.148; P.L.204-2018, SEC.1.

 

Notes of Decisions
Cited in 14 cases, 1980–2012 · leading case: Kenneth C. Vantine & Rebecca Vantine v. Elkhart Brass Mfg. Co., Inc. & Wausau Ins. Co., 762 F.2d 511 (7th Cir. 1985).
Kenneth C. Vantine & Rebecca Vantine v. Elkhart Brass Mfg. Co., Inc. & Wausau Ins. Co., 762 F.2d 511 (7th Cir. 1985). · cites it 3× “The Court premised its holding upon Ind.Code § 22-3-2-15 (1971) which provides: “No contract or agreement, written or implied, no rule, regulation or other device shall, in any manner, operate to relieve any employer in whole or in part of any obligation created by this act.”
Campbell v. Eli Lilly & Co., 413 N.E.2d 1054 (Ind. Ct. App. 1980). · cites it 2× “[2] Ind. Code 22-3-2-15. [1] See Comment: 1977 Wis.”
Niesent v. Homestake Mining Co. of California, 505 N.W.2d 781 (S.D. 1993). · cites it 2× “Ind.Code § 22-3-2-15 (1971) provided: No contract or agreement, written or implied, no rule, regulation or other device shall, in any manner, operate to relieve any employer in whole or in part of any obligation created by this act.”
Lawson v. Haven Hubbard Homes, Inc., 551 N.E.2d 855 (Ind. Ct. App. 1990). · cites it 3× “The court held the threat of discharge to be a prohibited "device" within the meaning of I.C. § 22-3-2-15. Lawson contends the "statutory right exception" announced in Frampton, supra, should be applied in the present case.”
Jane Doe v. Allied-Signal, Inc., 925 F.2d 1007 (7th Cir. 1991). “Ind.Code § 22-3-2-15(a). And §§ 22-3-2-2(a) and 22-3-2-6 bind employees to accept benefits payable through worker’s compensation as their exclusive remedy from their "employers.”
Mem'l Hosp. v. Szuba, 705 N.E.2d 519 (Ind. Ct. App. 1999). · cites it 2× “” Another example of a statute in the Act which refers to parents separately from guardians is Ind.Code § 22-3-2-15(c) which provides: “A minor dependent, by parent or legal guardian, may compromise disputes and may enter into a compromise settlement agreement, and upon approval…”
Goff v. Wal-Mart Stores, Inc., 719 N.E.2d 1260 (Ind. Ct. App. 1999). · cites it 10× “On November 4, 1994, Goff, represented by counsel, and Wal-Mart entered into a “Stipulation for Settlement” pursuant in part to Ind.Code § 22-3-2-15. The settlement agreement provides in pertinent part as follows: 2.”
Est. of Smith v. Stutzman, 964 N.E.2d 904 (Ind. Ct. App. 2012). · cites it 6× “This agreement is entered into by the parties as a compromise settlement agreement in order to gain approval thereof by the Board pursuant to Indiana Code § 22-3-2-15. [3] This agreement and stipula *910 tion shall be of no force or effect in the absence of an entry of an order…”
Freel v. Foster Forbes Glass Co., 449 N.E.2d 1148 (Ind. Ct. App. 1983). “The court relied on a statute that is the counterpart of Ind.Code 22-3-2-15, which reads in pertinent part: "No contract or agreement, written or implied, no rule, regulation or other device shall, in any manner, operate to relieve any employer in whole or in part of any…”
La Buhn v. Bulkmatic Transp. Co., 644 F. Supp. 942 (N.D. Ill. 1986). “Such a CBA-based cause of action was necessarily preempted by Section 301 {id.”
Orsini v. Echlin, Inc., 637 F. Supp. 38 (N.D. Ill. 1986). “shall, in any manner, operate to relieve any employer in whole or in part of any obligation created by this act” ( Ind. Code § 22-3-2-15 , as quoted (complete with emphasis) in Vantine v.”
Travelers Ins. Co. v. R.B. Carriers, Inc., 613 N.E.2d 440 (Ind. Ct. App. 1993). “CODE § 22-3-2-15(a) likewise negates the "Hold Harmless Clause" contained in the standard lease.”
— Ind. Code § 22-3-2-15(a) — 2 cases
Jane Doe v. Allied-Signal, Inc., 925 F.2d 1007 (7th Cir. 1991). “Ind.Code § 22-3-2-15(a). And §§ 22-3-2-2(a) and 22-3-2-6 bind employees to accept benefits payable through worker’s compensation as their exclusive remedy from their "employers.”
Travelers Ins. Co. v. R.B. Carriers, Inc., 613 N.E.2d 440 (Ind. Ct. App. 1993). “CODE § 22-3-2-15(a) likewise negates the "Hold Harmless Clause" contained in the standard lease.”
— Ind. Code § 22-3-2-15(c) — 1 case
Mem'l Hosp. v. Szuba, 705 N.E.2d 519 (Ind. Ct. App. 1999). “” Another example of a statute in the Act which refers to parents separately from guardians is Ind.Code § 22-3-2-15(c) which provides: “A minor dependent, by parent or legal guardian, may compromise disputes and may enter into a compromise settlement agreement, and upon approval…”
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.