Utah Code » Title 34A, Chapter 2 — Workers' Compensation Act; part 34A-2-4 — Compensation and Benefits
Utah Code

Utah Code § 34A-2-420 (2026)

Continuing jurisdiction of commission -- No authority to change statutes of limitation -- Authority to destroy records -- Interest on award -- Authority to approve final settlement claims

✓ current as of May 2026
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The powers and jurisdiction of the commission over each case is continuing.
After notice and hearing, the Division of Adjudication, commissioner, or Appeals Board in accordance with Part 8, Adjudication, may from time to time modify or change a former finding or order of the commission.
This section may not be interpreted as modifying the statutes of limitations contained in Section 34A-2-417 or other sections of this chapter or Chapter 3, Utah Occupational Disease Act, or authorizing the commission to change these statutes of limitations.
In addition to other settlements permissible under this chapter or Chapter 3, Utah Occupational Disease Act, and notwithstanding Subsection (1)(c), the commission may approve a full and final settlement of an employee's claim for compensation under this chapter or Chapter 3, Utah Occupational Disease Act, including the payment of medical and disability benefits, if:
the employee's claim for medical benefits is allowed under Subsection 34A-2-417(1), but the payment of disability benefits associated with the medical benefits and resulting treatment is barred pursuant to Subsection 34A-2-417(2); and
the full and final settlement is presented to the commission for approval; or
an employee's claim for compensation under this chapter or Chapter 3, Utah Occupational Disease Act, is the liability of the Employers' Reinsurance Fund created in Section 34A-2-702 or the Uninsured Employers' Fund created in Section 34A-2-704.
A record pertaining to a case that has been closed and inactive for 10 years, other than a case of total permanent disability or a case in which a claim has been filed as in Section 34A-2-417, may be destroyed at the discretion of the commission.
An award made by a final order of the commission shall include interest at the rate of 8% per annum from the date when each benefit payment would have otherwise become due and payable.
Notwithstanding Subsection (1) and Section 34A-2-108, an administrative law judge shall review and may approve the agreement of the parties to enter into a full and final settlement by means of a:
compromise settlement of disputed medical, disability, or death benefit entitlements under this chapter or Chapter 3, Utah Occupational Disease Act; or
commutation and settlement of reasonable future medical, disability, or death benefit entitlements under this chapter or Chapter 3, Utah Occupational Disease Act, by means of a lump sum payment, structured settlement, or other appropriate payout.
A full and final settlement approved under this section shall extinguish the employer's liability to the employee under this chapter and Chapter 3, Utah Occupational Disease Act, except for an issue that is expressly preserved.
A full and final settlement effectuating a compromise or commutation may provide for payment of benefits:
in cash or cash equivalents; or
through an insurance contract or by a third party if the commission determines that the payment provisions:
are secure and assign, transfer, or reinsure the financial obligation to make benefit payments to a qualified third party in compliance with commission rules; or
do not relieve the parties of their underlying liability for payments required by the full and final settlement agreement.
Notes of Decisions
Cited in 17 cases (3 in the last 5 years), 1998–2025 · leading case: Touchard v. La-Z-Boy Inc., 2006 UT 71 (Utah 2006).
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Touchard v. La-Z-Boy Inc., 2006 UT 71 (Utah 2006). · cites it 5× “We note that section 34A-2-108 does provide for the settlement of workers’ compensation claims in accordance with Utah Code section 34A-2-420. Section 34A-2-420(4) permits the parties to agree to a "settlement of disputed medical, disability, or death benefit entitlements” or…”
Waite v. Utah Labor Comm'n, 2017 UT 86 (Utah 2017). · cites it 3× “Utah Code § 34A-2-420(1)(a). Id. § 34A-2-420(1)(b).”
Frito-Lay v. Utah Labor Comm'n, 2009 UT 71 (Utah 2009). · cites it 4× “, Utah Code Ann. § 34A-2-420 (2005) (setting procedures specific to Labor Commission adjudications); see also Utah Chiropractic Ass'n v.”
Thomas v. Color Country Mgmt., 2004 UT 12 (Utah 2004). · cites it 2× “[1] Although the statutory amendment adding the "final order" requirement became effective on July 1, 1997 and the statute of limitations for workers' compensation cases is generally six years, see Utah Code Ann.”
Color Country Mgmt. v. Labor Comm'n, 2001 UT App 370 (Utah Ct. App. 2001). · cites it 2× “§ 35-1-78 (1) (1994) (currently codified at Utah Code Ann. § 34A-2-420(1) (1997)); Continental Casualty Co.”
Merrill v. Utah Labor Comm'n, 2009 UT 74 (Utah 2009). · cites it 2× “*1103 While the Labor Commission has continuing jurisdiction pursuant to Utah Code section 34A-2-420, it lacks the authority to reopen workers compensation proceedings to consider legal arguments not previously made.”
Christopher R. Brown, D.D.S., Inc. v. Decatur Cnty. Mem'l Hosp., 892 N.E.2d 642 (Ind. 2008). “064 (Vernon 2006); Utah Code Ann. § 34A-2-420(3) (2005); Va.”
Strate v. Labor Comm'n, 2006 UT App 179 (Utah Ct. App. 2006). · cites it 6× “” However, under Utah Code section 34A-2-420, "records pertaining to cases that have been closed and inactive for ten years, other than cases of total permanent disability or cases in which a claim has been filed as in section 34A-2-417, may be destroyed at the discretion of the…”
Potomac Abatement, Inc. v. Sanchez, 37 A.3d 972 (Md. 2012). “§ 35-1-78 (current version at Utah Code Ann. § 34A-2-420(b)); Cal. Lab.”
Burgess v. Siaperas Sand & Gravel, 965 P.2d 583 (Utah Ct. App. 1998). · cites it 2× “Currently, Utah Code Ann. § 34A-2-420 (1997). 5 . Currently, Utah Code Ann.”
Rowsell v. Labor Comm'n, 186 P.3d 968 (Utah Ct. App. 2008). · cites it 3× “§ 34A-1-309(3), (4), and section 34A-2-420 grants the Commission the ability to reject parties' settlement agreements altogether, which necessarily includes agreements parties make regarding attorney fees, see id.”
Barnard & Burk Grp., Inc. v. Labor Comm'n, 122 P.3d 700 (Utah Ct. App. 2005). · cites it 2× “See Utah Code Ann. § 34A-2-420(l) (2001); see also United States Fid.”
Show all 17 citing cases →
— Utah Code § 34A-2-420(1) — 2 cases
Color Country Mgmt. v. Labor Comm'n, 2001 UT App 370 (Utah Ct. App. 2001). “§ 35-1-78 (1) (1994) (currently codified at Utah Code Ann. § 34A-2-420(1) (1997)); Continental Casualty Co.”
C.R. England v. Hakem, 2021 UT App 108 (Utah Ct. App. 2021).
— Utah Code § 34A-2-420(1)(a) — 2 cases
Waite v. Utah Labor Comm'n, 2017 UT 86 (Utah 2017). “Utah Code § 34A-2-420(1)(a). Id. § 34A-2-420(1)(b).”
Carradine v. Labor Comm'n, 2011 UT App 212 (Utah Ct. App. 2011).
— Utah Code § 34A-2-420(1)(b) — 2 cases
Waite v. Utah Labor Comm'n, 2017 UT 86 (Utah 2017). “Utah Code § 34A-2-420(1)(a). Id. § 34A-2-420(1)(b).”
Frito-Lay & Transcontinental Ins. Co v. Labor Comm'n, 2008 UT App 314 (Utah Ct. App. 2008).
— Utah Code § 34A-2-420(2) — 1 case
Strate v. Labor Comm'n, 2006 UT App 179 (Utah Ct. App. 2006). “” However, under Utah Code section 34A-2-420, "records pertaining to cases that have been closed and inactive for ten years, other than cases of total permanent disability or cases in which a claim has been filed as in section 34A-2-417, may be destroyed at the discretion of the…”
— Utah Code § 34A-2-420(3) — 1 case
Christopher R. Brown, D.D.S., Inc. v. Decatur Cnty. Mem'l Hosp., 892 N.E.2d 642 (Ind. 2008). “064 (Vernon 2006); Utah Code Ann. § 34A-2-420(3) (2005); Va.”
— Utah Code § 34A-2-420(4) — 3 cases
Touchard v. La-Z-Boy Inc., 2006 UT 71 (Utah 2006). “We note that section 34A-2-108 does provide for the settlement of workers’ compensation claims in accordance with Utah Code section 34A-2-420. Section 34A-2-420(4) permits the parties to agree to a "settlement of disputed medical, disability, or death benefit entitlements” or…”
Rowsell v. Labor Comm'n, 186 P.3d 968 (Utah Ct. App. 2008). “§ 34A-1-309(3), (4), and section 34A-2-420 grants the Commission the ability to reject parties' settlement agreements altogether, which necessarily includes agreements parties make regarding attorney fees, see id.”
Waxies Enter. v. Labor Comm'n, 2025 UT App 7 (Utah Ct. App. 2025).
— Utah Code § 34A-2-420(b) — 1 case
Potomac Abatement, Inc. v. Sanchez, 37 A.3d 972 (Md. 2012). “§ 35-1-78 (current version at Utah Code Ann. § 34A-2-420(b)); Cal. Lab.”
— Utah Code § 34A-2-420(l) — 1 case
Barnard & Burk Grp., Inc. v. Labor Comm'n, 122 P.3d 700 (Utah Ct. App. 2005). “See Utah Code Ann. § 34A-2-420(l) (2001); see also United States Fid.”
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