Specialty Restaurants Corp. and Colorado Insurance Guaranty Association C/o Western Guaranty Fund Services V…

Summary

The court held that the 2007 amendment increasing the maximum aggregate lump-sum payment for permanent-total-disability benefits was procedural because it changed only the method and timing of distributing an existing award. The amendment therefore applied prospectively to requests made after enactment, regardless of the date of injury, entitling Nelson to the additional payment. The court also rejected and overruled contrary precedent to the extent inconsistent with this analysis. Justice RICE, concurring in part and dissenting in part, would have treated the amendment as substantive and denied the additional payment.