Steve L. Michaud v. Caribou Ford-Mercury, Inc.

Summary

The court held that Michaud’s specific-loss benefits for his eye injury became due on the date of injury because his vision loss immediately exceeded the statutory threshold and never improved below it. Although eligibility could not be determined until the injury reached its reasonable medical endpoint, that endpoint did not establish the benefits’ due date, so interest accrued from the injury date through payment. The court vacated and remanded for recalculation consistent with that rule, while recognizing that the parties’ settlement agreement governed the employer’s credit for prior voluntary payments.