Tennessee Code Annotated
Tenn. Code Ann. § 50-6-229 (2026)
Commutation to lump sum payment with consent of court
✓ current as of May 2026
- (a) The amounts of compensation payable periodically under this chapter may be commuted to one (1) or more lump sum payments. These may be commuted upon motion of any party subject to the approval of the court of workers' compensation claims. No agreed stipulation or order or any agreement by the employer and employee or any other party to the proceeding shall be a prerequisite to the court's approval or disapproval of the award being paid in one (1) or more lump sum payments. In making the commutation, the lump sum payment shall, in the aggregate, amount to a sum of all future installments of compensation. No settlement or compromise shall be made except on the terms provided in this chapter. In determining whether to commute an award, the trial court shall consider whether the commutation will be in the best interest of the employee, and the court shall also consider the ability of the employee to wisely manage and control the commuted award, regardless of whether special needs exist. Attorneys' fees may be paid as a partial lump sum from any award when approved and ordered by the trial judge.
- (b) All settlements of compensation by agreement of the parties and all awards of compensation made by the court of workers' compensation claims, when the amount paid or to be paid in settlement or by award does not exceed the compensation for twenty-six (26) weeks of disability, shall be final and not subject to readjustment.
- (c) All amounts paid by the employer and received by the employee or the employee's dependents, by lump sum payments, shall be final, but the amount of any award payable periodically for more than twenty-six (26) weeks may be modified as follows:
- (1) At any time by agreement of the parties and approval by the court; or
- (2) If the parties do not agree, then at any time after twenty-six (26) weeks from the date of the award, either party may file an application to the court of workers' compensation claims, on the ground of increase or decrease of incapacity due solely to the injury.
Acts 1919, ch. 123, § 36; Shan. Supp., § 3608a186; Code 1932, § 6890; Acts 1947, ch. 139, § 12; C. Supp. 1950, § 6890; Acts 1971, ch. 300, § 2; 1979, ch. 295, § 1; impl. am. Acts 1980, ch. 534, § 1; T.C.A. (orig. ed.), § 50-1023; Acts 1983, ch. 217, § 5; 1985, ch. 393, § 16; 1990, ch. 843, § 1; 1992, ch. 900, § 25; 1999, ch. 520, § 41; 2013, ch. 289, §§ 67, 68; 2016, ch. 816, § 7.
Notes of Decisions
Cited in 44
cases (10 in the last 5 years), 1984–2025 · leading case: Leab v. S & H Mining Co., 76 S.W.3d 344 (Tenn. 2002).
Leab v. S & H Mining Co., 76 S.W.3d 344 (Tenn. 2002). “Under Tenn.Code Ann. § 50-6-229 (1999), the trial court must engage in a two-pronged analysis when considering whether to commute an award to a lump sum.”
North Am. Royalties, Inc. v. Thrasher, 817 S.W.2d 308 (Tenn. 1991). “In 1990, the requirement of judicial inquiry was codified by an amendment to T.C.A. § 50-6-229 governing lump-sum payments.”
Perdue v. Green Branch Min. Co., Inc., 837 S.W.2d 56 (Tenn. 1992). “Before the 1990 amendment to Tenn. Code Ann. § 50-6-229 , with a proper factual basis, however, this Court approved lump-sum awards for the purpose of allowing an injured employee to purchase a home.”
Jones v. Gen. Accident Ins. Co. of Am., 856 S.W.2d 133 (Tenn. 1993). “On the other hand, as the Plaintiff points out, T.C.A. § 50-6-229, the statute authorizing commutation of compensation payable periodically, does not exclude from its scope death benefits to dependents.”
Lock v. Nat'l Union Fire Ins. Co., 809 S.W.2d 483 (Tenn. 1991). “The Plaintiff may file a motion in the Chancery Court pursuant to T.C.A. § 50-6-229, seeking commutation to one or more lump sums if he can show a *489 sufficient change in circumstances necessitating such a commutation.”
Edmonds v. Wilson Cnty., 9 S.W.3d 106 (Tenn. 1999). “Tenn. Code Ann. § 50-6-229 (a). The controlling statute, TenmCode Ann.”
Henson v. City of Lawrenceburg, 851 S.W.2d 809 (Tenn. 1993). “” Tenn.Code Ann. § 50-6-229(a) (1991 & Supp.”
Clayton v. Cookeville Energy, Inc., 824 S.W.2d 167 (Tenn. 1992). “With respect to the plaintiff’s share, the trial court found that a lump sum payment would be in the best interest of the plaintiff and her minor children, and that she had demonstrated the required ability to wisely manage and control a lump sum, pursuant to Tenn.Code Ann. §…”
Lindsey v. Strohs Companies, 830 S.W.2d 899 (Tenn. 1992). “Under a recent amendment to Tenn.Code Ann. § 50-6-229(a), effective July 1, 1990, the factors which Tennessee courts must consider are somewhat altered.”
Newton v. Scott Health Care Ctr., 914 S.W.2d 884 (Tenn. 1995). “The standard for award of lump sum payment is set out in Tenn.Code Ann. § 50-6-229. The statute provides: *887 In determining whether to commute an award, the trial court shall consider whether the commutation will be in the best interest of the employee, and such court shall…”
Van Hooser v. Mueller Co., 741 S.W.2d 329 (Tenn. 1987). “T.C.A. § 50-6-229. The decision of whether to commute an award to a lump sum is left to the discretion of the trial court.”
Burris v. Cross Mountain Coal Co., 798 S.W.2d 746 (Tenn. 1990). “T.C.A. § 50-6-229(a). 3 Demonstrating an adequate need for housing can justify commuting an award into a lump sum that would otherwise be paid weekly.”
— Tenn. Code Ann. § 50-6-229(a) — 27 cases
Perdue v. Green Branch Min. Co., Inc., 837 S.W.2d 56 (Tenn. 1992). “Before the 1990 amendment to Tenn. Code Ann. § 50-6-229 , with a proper factual basis, however, this Court approved lump-sum awards for the purpose of allowing an injured employee to purchase a home.”
Leab v. S & H Mining Co., 76 S.W.3d 344 (Tenn. 2002). “Under Tenn.Code Ann. § 50-6-229 (1999), the trial court must engage in a two-pronged analysis when considering whether to commute an award to a lump sum.”
Henson v. City of Lawrenceburg, 851 S.W.2d 809 (Tenn. 1993). “” Tenn.Code Ann. § 50-6-229(a) (1991 & Supp.”
North Am. Royalties, Inc. v. Thrasher, 817 S.W.2d 308 (Tenn. 1991). “In 1990, the requirement of judicial inquiry was codified by an amendment to T.C.A. § 50-6-229 governing lump-sum payments.”
Clayton v. Cookeville Energy, Inc., 824 S.W.2d 167 (Tenn. 1992). “With respect to the plaintiff’s share, the trial court found that a lump sum payment would be in the best interest of the plaintiff and her minor children, and that she had demonstrated the required ability to wisely manage and control a lump sum, pursuant to Tenn.Code Ann. §…”
— Tenn. Code Ann. § 50-6-229(c) — 1 case
Oldham, John v. Freeman Webb Co. Realtors d/b/a Sunnybrook, 2024 TN WC App. 41 (Tenn. Work. Comp. App. Bd. 2024).
— Tenn. Code Ann. § 50-6-229(c)(1) — 1 case
Bragg, Robert v. Premium Servs., LLC, 2023 TN WC App. 34 (Tenn. Work. Comp. App. Bd. 2023).
— Tenn. Code Ann. § 50-6-229(c)(2) — 1 case
Bragg, Robert v. Premium Servs., LLC, 2023 TN WC App. 34 (Tenn. Work. Comp. App. Bd. 2023).
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