Wisconsin Statutes
Wis. Stat. § 102.56 (2026)
Disfigurement
✓ current as of July 2026
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102.56(1)(1) Subject to sub. (2), if an employee is so permanently disfigured as to occasion potential wage loss due to the disfigurement, the department may allow such sum as the department considers just as compensation for the disfigurement, not exceeding the employee’s average annual earnings. In determining the potential for wage loss due to the disfigurement and the sum awarded, the department shall take into account the age, education, training, and previous experience and earnings of the employee, the employee’s present occupation and earnings, and likelihood of future suitable occupational change. Consideration for disfigurement allowance is confined to those areas of the body that are exposed in the normal course of employment. The department shall also take into account the appearance of the disfigurement, its location, and the likelihood of its exposure in occupations for which the employee is suited.
102.56(2)(2) If an employee who claims compensation under sub. (1) returns to work for the employer who employed the employee at the time of the injury, or is offered employment with that employer, at the same or a higher wage, the department may not allow that compensation unless the employee suffers an actual wage loss due to the disfigurement.
102.56 AnnotationThe Labor and Industry Review Commission’s allowance of a disfigurement award based on a limp was a reasonable interpretation of this section. Nothing in sub. (1) limits disfigurement to amputations, scars, and burns. County of Dane v. LIRC, 2009 WI 9, 315 Wis. 2d 293, 759 N.W.2d 571, 06-2695.
Notes of Decisions
Cited in 6
cases, 1983–2010 · leading case: Cnty. of Dane v. Labor & Indus. Review Comm'n, 2009 WI 9 (Wis. 2009).
Cnty. of Dane v. Labor & Indus. Review Comm'n, 2009 WI 9 (Wis. 2009). “We review a decision of the court of appeals [1] affirming the circuit court's decision, [2] which affirmed the Labor and Industry Review Commission's (LIRC) order directing that Gloria Graham (Graham) is eligible to receive a statutory award for permanent disfigurement under…”
Cnty. of Dane v. Labor & Indus. Review Comm'n, 2007 WI App 262 (Wis. Ct. App. 2007). “The operative statute, Wis. Stat. § 102.56 (1) (2005-06), 2 provides, in relevant part, as follows: If an employee is so permanently disfigured as to occasion potential wage loss, the department may allow such sum as it deems just as compensation therefor .”
Kenwood Merchandising Corp. v. Labor & Indus. Review Comm'n, 338 N.W.2d 312 (Wis. Ct. App. 1983). “On appeal Kenwood raises the following issues: (1) whether there was sufficient evidence established to support the finding that Warwick was entitled to a loss of earnings award due to disfigurement pursuant to sec. 102.56, Stats. (1975) ; (2) whether the LIRC is authorized to…”
Eaton Corp. v. Labor & Indus. Review Comm'n, 364 N.W.2d 172 (Wis. Ct. App. 1985). “It is apparent, however, that the examiner considered all the factors listed in sec. 102.56, Stats., in determining that Pabelick was entitled to an award for potential wage loss due to disfigurement.”
Evans Bros. Co. v. Labor & Indus. Review Comm'n, 335 N.W.2d 886 (Wis. Ct. App. 1983). “The issues are whether the Commission reached a reasonable legal conclusion when it decided that Palmer’s scars would “occasion potential loss of wage” within the meaning of sec. 102.56, Stats. (1975), and whether the Commission correctly calculated the amount of Palmer’s award…”
Cnty. of Barron v. Labor & Indus. Review Comm'n, 2010 WI App 149 (Wis. Ct. App. 2010). “The County primarily relies on County of Dane , in which our supreme court declined to give any deference to the Commission's conclusion that an injured individual's limp constituted a permanent disfigurement under Wis. Stat. § 102.56 (1) (2005-06). County of Dane, 315 Wis.”
— Wis. Stat. § 102.56(1) — 3 cases
Cnty. of Dane v. Labor & Indus. Review Comm'n, 2009 WI 9 (Wis. 2009). “We review a decision of the court of appeals [1] affirming the circuit court's decision, [2] which affirmed the Labor and Industry Review Commission's (LIRC) order directing that Gloria Graham (Graham) is eligible to receive a statutory award for permanent disfigurement under…”
Cnty. of Dane v. Labor & Indus. Review Comm'n, 2007 WI App 262 (Wis. Ct. App. 2007). “The operative statute, Wis. Stat. § 102.56 (1) (2005-06), 2 provides, in relevant part, as follows: If an employee is so permanently disfigured as to occasion potential wage loss, the department may allow such sum as it deems just as compensation therefor .”
Cnty. of Barron v. Labor & Indus. Review Comm'n, 2010 WI App 149 (Wis. Ct. App. 2010). “The County primarily relies on County of Dane , in which our supreme court declined to give any deference to the Commission's conclusion that an injured individual's limp constituted a permanent disfigurement under Wis. Stat. § 102.56 (1) (2005-06). County of Dane, 315 Wis.”
— Wis. Stat. § 102.56(2) — 1 case
Cnty. of Dane v. Labor & Indus. Review Comm'n, 2009 WI 9 (Wis. 2009). “We review a decision of the court of appeals [1] affirming the circuit court's decision, [2] which affirmed the Labor and Industry Review Commission's (LIRC) order directing that Gloria Graham (Graham) is eligible to receive a statutory award for permanent disfigurement under…”
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