## Facts

- William Duni worked for United Technologies Corporation/Pratt & Whitney Aircraft Division from 1941 to 1982.
- In 1984, he filed a workers’ compensation claim alleging disability from workplace exposure to substances.
- The claim was settled for $72,000 by a written stipulation approved by a workers’ compensation commissioner.
- The stipulation broadly released the employer from “any and all further claims” and purported to bar “any further liability to anybody” arising from the claimed injuries and resulting conditions.
- William Duni died in 1991.
- His widow, Beatrice Duni, filed a claim for survivor’s benefits under Conn. Gen. Stat. § 31-306, alleging his death was causally related to the occupational injuries.
- The employer and insurer asserted the prior stipulation barred the widow’s claim; the widow argued her § 31-306 right was independent and she did not sign the stipulation.

## Issues

1. Whether an employee’s workers’ compensation stipulation and release—purporting to discharge the employer from all future claims by “anybody” arising from the employee’s injuries—bars a surviving spouse’s later claim for statutory survivor’s benefits under Conn. Gen. Stat. § 31-306.

## Decision

- The Connecticut Supreme Court reversed the Compensation Review Board.
- The Court held the widow’s § 31-306 claim was not barred by the employee’s prior stipulation and release.
- The case was remanded for adjudication of the survivor’s benefits claim on the merits (rather than dismissal based on the release).

## Legal Principles

- Conn. Gen. Stat. § 31-306 creates a dependent’s right to survivor’s benefits that is separate from, and not derivative of, the employee’s disability compensation claim.
- A dependent’s § 31-306 claim does not vest until the employee’s compensable death; it cannot be waived in advance through the employee’s settlement of his own claim.
- A settlement and release can extinguish only claims the settling party owns or has authority to compromise; an employee lacks authority to waive dependents’ independent statutory rights.
- Broad contractual release language (“to anybody”) cannot override statutory allocation of rights under the Workers’ Compensation Act.
- The Workers’ Compensation Act is remedial and is construed liberally to protect employees and their dependents; allowing employees to bargain away dependents’ future death benefits would conflict with that purpose.

## Conclusion

A workers’ compensation settlement resolving an employee’s disability claim, even with sweeping release language, does not extinguish a surviving spouse’s independent statutory right to pursue survivor’s benefits under Conn. Gen. Stat. § 31-306 after the employee’s compensable death.


Duni v. United Techs. Corp./Pratt & Whitney Aircraft Div., 239 Conn. 19, 682 A.2d 99 (1996)