US Dist Ct: Vt Workers' Compensation Act provision re death benefits does not violate Vt Constitution's Common Benefits clause

Vermont’s Workers’ Compensation Act provides benefits for the dependents of workers who die as a result of injuries sustained on the job. But non-dependent next of kin receive nothing, 21 V.S.A. § 634, and are barred from suing the employer. 12 V.S.A. § 622. In Samaha v. Scott’s Construction, No. 2:05-cv-315, 2008 WL 516417 (D.Vt. Feb. 22, 2008) (Sessions, Chief Judge), the Court ruled that the Act’s distinction between dependents and non-dependent next of kin does not violate the Common Benefits clause of Vermont’s Constitution, Ch. I, Art. 7.