In Carr v North Kansas City Beverage Company, 49 S.W.3d 205 (Mo.App. W.D., 2001), the deceased claimant appealed the order of the LIRC denying Appellant’s Motion to Compel Compliance with Award Regarding Interest on death benefits and funeral expenses awarded by the Commission to Appellant’s widow and minor child. The Court of Appeals, in dismissing Appellant’s appeal, found that the Commission was correct in denying Appellant’s motion because it lacked authority to compel compliance with the Commission’s award.

In Sutton v Vee Jay Cement Contracting Co., 37 S.W.3d 803 (Mo.App. E.D. 2000), the Court held that the claimant was entitled to interest on temporary total disability benefits that the employer was delinquent in paying. In denying the claimant’s point that there was no specific determination of the amount of interest to be paid, the Court of Appeals found that the amount of interest awarded by the Commission could be determined from the examination of the record and applicable statute. The Court of Appeals also held that there was substantial and competent evidence to affirm the Commissions’ decision to deny the claimant future medical benefits, and to find the claimant not permanent and totally disabled. The Court, though, did remand for the Commission to calculate the amount of the entire award to be doubled for failure of the employer to comply with the second temporary award under Section 287.510.

In Pemberton v 3M Co., 992 S.W.2d 365 (Mo.App. W.D. 1999), the Court held that where a claimant cannot establish that his medical expenses are due, he is unable to recover prejudgment interest on those medical bills.