Utah Statute Reducing Workers Compensation Benefits for Social Security Retirement Benefits Found Unconstitutional.

In Merrill v. Utah Labor Commission, the Utah Supreme Court ruled that the Utah Workers Compensation statutory provision that requires the reduction of workers compensation benefits by 50% of the Social Security retirement benefits received by an injured worker was unconstitutional under the “uniform operations of law” clause or article I, section 24 of the Utah Constitution. Although the Court pointed out in its opinion that several other states’ supreme courts had determined that such a legislative policy did not violate similar constitutional provisions, the Utah Supreme Court concluded that it was simply “not rational” for the legislature to offset workers compensation benefits with social security retirement benefits.