logical cause doctrine (Florida) · Go Syfert
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logical cause doctrine in Florida

17 Florida opinions name it 1 courts 1980–1994 0 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Wilhelm v. Westminster Presbyterian Churchgreen
fla · 1970 · cited in 7 Florida opinions naming this issue, 1980–1991
2 sentences

1990Contrary to the conclusion of the judge, we must agree with claimant that Dr. Mitchell’s testimony was sufficient to invoke the logical cause doctrine as enunciated in Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla.1970).

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

17
Deahl v. Uni-Pak Corp.green
fladistctapp · 1989 · cited in 2 Florida opinions naming this issue, 1989–1993
2 sentences

1993See, e.g., Deahl v. Uni-Pak Corp., 550 So.2d 122 (Fla. 1st DCA 1989).

1989For the logical cause doctrine to be applicable, "the claimant must prove a causal connection between his employment and the injury by competent, substantial evidence." Deahl v. Uni-Pak Corp., 550 So.2d 122 (Fla. 1st DCA 1989).

12
Bahr v. Howard Johnsongreen
fladistctapp · 1986 · cited in 2 Florida opinions naming this issue, 1987–1988
2 sentences

1988As did the employer/carrier in Manley , the employer/carrier in the instant case cite to Bahr v. Howard Johnson, 498 So.2d 518 (Fla. 1st DCA 1986), for the proposition that the deputy was entitled to reject claimant's evidence regarding causation and choose not to apply the logical cause doctrine where he found claimant lacked credibility.

1987See Bahr v. Howard Johnson #24609, 498 So.2d 518 (Fla. 1st DCA 1986); Barnett v. Lakeland Construction Co., 417 So.2d 834 (Fla. 1st DCA 1982).

12
Foxworth v. Florida Industrial Commissiongreen
fla · 1955 · cited in 1 Florida opinions naming this issue, 1993–1993
1 sentence

1993See also Foxworth v. Florida Industrial Comm’n, 86 So.2d 147 (Fla.1955).

11
Ullman v. City of Tampa Parks Dept.green
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 1993–1993
1 sentence

1993See Ullman, supra. The determination of compensability in this case depends on the finding as to claimant’s credibility, and several of the reasons the JCC gave for rejecting claimant’s testimony as not credible are not supported in the record.

11
Glasrock Home Health Care v. Leivagreen
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 1991–1991
1 sentence

1991In Glasrock Home Health Care v. Leiva, 578 So.2d 776, 778 (Fla. 1st DCA 1991), this court likewise held evidence of causation must be shown by something more than a logical relationship.

11
Wiley v. Southeast Erectors, Inc.green
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 1991–1991
1 sentence

1991Claimant relies on the logical cause doctrine to establish causation; however, this court has held that “the evidence of causation must be shown by something more than that it is merely logical that the injury arose out of employment.” Wiley v. Southeast Erectors, Inc., 573 So.2d 946, 948 (Fla. 1st DCA 1991), rev. denied, 582 So.2d 623 (Fla. May 5, 1991).

11
City of Ft. Lauderdale v. Lindiegreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 1989–1989
2 sentences

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

11
Logan v. Poe's Hardware & Rentalsgreen
fladistctapp · 1980 · cited in 1 Florida opinions naming this issue, 1983–1983
1 sentence

1983As to "logical cause," generally, see Fisher v. Carroll Daniel Fisher Construction Co., 212 So.2d 289 (Fla. 1968); Logan v. Poe's Hardware & Rentals, 381 So.2d 1170 *165 (Fla. 1st DCA 1980); and see, also, Lake v. Irwin Yacht & Marine Corp., 398 So.2d 902 (Fla. 1st DCA 1981), which impliedly, though not expressly, relied upon the logical cause doctrine to establish causation in an exposure case. [6] The E/C challenge the deputy commissioner's finding that the absence of noise level tests is not fatal to the claimant's case.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Bray v. Electronic Door-Lift, Inc. green
fladistctapp · 1989
2 sentences

1994Id. at 47 .

1993This court in Bray did find the logical cause doctrine to be "applicable." 558 So.2d at 46 .

21993–1994
Schafrath v. Marco Bay Resort, Ltd. green
fladistctapp · 1992
1 sentence

1994The claimant maintains that she presented a prima facie case so as to invoke the doctrine in accordance with Schafrath v. Marco Bay Resort, 608 So.2d 97 (Fla. 1st DCA 1992), and Johnson v. Koffee Kettle Restaurant, 125 So.2d 297 (Fla.1960).

11994–1994
Johnson v. Koffee Kettle Restaurant green
fla · 1960
1 sentence

1994The claimant maintains that she presented a prima facie case so as to invoke the doctrine in accordance with Schafrath v. Marco Bay Resort, 608 So.2d 97 (Fla. 1st DCA 1992), and Johnson v. Koffee Kettle Restaurant, 125 So.2d 297 (Fla.1960).

11994–1994
Manley v. Bennett's Truck Equipment green
fladistctapp · 1987
1 sentence

1993They pursued their claims under the repetitive trauma theory approved in Festa v. Teleflex, Inc., 382 So.2d 122 (Fla. 1st DCA), rev. denied, 388 So.2d 1119 (Fla.1980), and sought application of the logical cause doctrine in accordance with cases such as Manley v. Bennett’s Truck Equip., 506 So.2d 1145 (Fla. 1st DCA), rev. denied, 518 So.2d 1273 (Fla.1987).

11993–1993
Festa v. Teleflex, Inc. green
fladistctapp · 1980
1 sentence

1993They pursued their claims under the repetitive trauma theory approved in Festa v. Teleflex, Inc., 382 So.2d 122 (Fla. 1st DCA), rev. denied, 388 So.2d 1119 (Fla.1980), and sought application of the logical cause doctrine in accordance with cases such as Manley v. Bennett’s Truck Equip., 506 So.2d 1145 (Fla. 1st DCA), rev. denied, 518 So.2d 1273 (Fla.1987).

11993–1993
Bean v. Cochran neutral
fla · 1962
1 sentence

1992Everhart Masonry, Inc. v. Crowder, 139 So.2d 393 (Fla.1962).

11992–1992
Poorman v. Muncy & Bartle Painting green
fladistctapp · 1983
2 sentences

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

11989–1989
ERB Building Systems v. Crowe neutral
fladistctapp · 1982
2 sentences

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

1989Under the logical cause doctrine, "[w]here an injury is shown, and the evidence presents a sufficiently logical explanation of a causal relationship between the accident and the subsequent injury, the burden shifts to the employer/carrier to show a more logical cause." Wilhelm v. Westminster Presbyterian Church, 235 So.2d 726 (Fla. 1970); City of Fort Lauderdale v. Lindie, 496 So.2d 168, 169 (Fla. 1st DCA 1986) review denied, 506 So.2d 1042 (Fla. 1987); Poorman v. Muncy & Bartle Painting, 433 So.2d 1371 (Fla. 1st DCA 1983); Erb Building Systems v. Crowe, 416 So.2d 849 (Fla. 1st DCA 1982).

11989–1989
Barnett v. Lakeland Construction Co. green
fladistctapp · 1982
1 sentence

1987See Bahr v. Howard Johnson #24609, 498 So.2d 518 (Fla. 1st DCA 1986); Barnett v. Lakeland Construction Co., 417 So.2d 834 (Fla. 1st DCA 1982).

11987–1987
Ralosky v. Dynamic Builders, Inc. green
fladistctapp · 1986
2 sentences

1987As this court observed in Ralosky v. Dynamic Builders, Inc., 500 So.2d 193 (Fla. 1st DCA 1986), cases involving the logical cause doctrine are not simply questions of CSE: The issue before us, however, does not depend simply upon whether the findings on review are supported by competent, substantial evidence.

1987As this court observed in Ralosky v. Dynamic Builders, Inc., 500 So.2d 193 (Fla. 1st DCA 1986), cases involving the logical cause doctrine are not simply questions of CSE: The issue before us, however, does not depend simply upon whether the findings on review are supported by competent, substantial evidence.

11987–1987
Fisher v. Carroll Daniel Fisher Construction Co. green
fla · 1968
1 sentence

1983As to "logical cause," generally, see Fisher v. Carroll Daniel Fisher Construction Co., 212 So.2d 289 (Fla. 1968); Logan v. Poe's Hardware & Rentals, 381 So.2d 1170 *165 (Fla. 1st DCA 1980); and see, also, Lake v. Irwin Yacht & Marine Corp., 398 So.2d 902 (Fla. 1st DCA 1981), which impliedly, though not expressly, relied upon the logical cause doctrine to establish causation in an exposure case. [6] The E/C challenge the deputy commissioner's finding that the absence of noise level tests is not fatal to the claimant's case.

11983–1983
Lake v. Irwin Yacht & Marine Corp. green
fladistctapp · 1981
1 sentence

1983As to "logical cause," generally, see Fisher v. Carroll Daniel Fisher Construction Co., 212 So.2d 289 (Fla. 1968); Logan v. Poe's Hardware & Rentals, 381 So.2d 1170 *165 (Fla. 1st DCA 1980); and see, also, Lake v. Irwin Yacht & Marine Corp., 398 So.2d 902 (Fla. 1st DCA 1981), which impliedly, though not expressly, relied upon the logical cause doctrine to establish causation in an exposure case. [6] The E/C challenge the deputy commissioner's finding that the absence of noise level tests is not fatal to the claimant's case.

11983–1983

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