contributing cause standard in Florida

2013Accordingly, the order on appeal is reversed and this case is remanded for entry of an order authorizing the surgical spine fusion.”); see also Caputo v. ABC Fine Wine & Spirits, 93 So.3d 1097, 1098 (Fla. 1st DCA 2012) (stating if “ ‘there was only one cause of claimant’s injuries, rather than competing causes, claimant was not required to present additional evidence going to the issue of whether the work-related accident was the major contributing cause of the injuries.’ ” (quoting Lanham, 868 So.2d at 563 )).

2012In the absence of competing causes of Claimant’s accident injuries, Claimant satisfied the major contributing cause requirement. ...” Id. at 1099 .

2013Prot., 868 So.2d 561, 563 (Fla. 1st DCA 2004) (“In that the record discloses there was only one cause of claimant’s injuries, rather than competing causes, claimant was not required to present additional evidence going to the issue of whether the work-related accident was the major contributing cause of the injuries.”); Bysczynski v. United Parcel Servs., Inc., 53 So.3d 328, 331 (Fla. 1st DCA 2010) (“In sum, because all the medical evidence establishes that the only contributing causes of Claimant’s need for the cervical spine fusion were occupational in nature, the JCC erred in applying the m

2012As we explained in Bysczynski v. United Parcel Services, Inc., 53 So.3d 328, 331 (Fla. 1st DCA 2010), it would have been error for the JCC to apply a major contributing cause analysis “because all of the medical evidence establishes that the only contributing causes of Claimant’s need for [benefits] were occupational in nature.” AFFIRMED.

2013Prot., 868 So.2d 561, 563 (Fla. 1st DCA 2004) (“In that the record discloses there was only one cause of claimant’s injuries, rather than competing causes, claimant was not required to present additional evidence going to the issue of whether the work-related accident was the major contributing cause of the injuries.”); Bysczynski v. United Parcel Servs., Inc., 53 So.3d 328, 331 (Fla. 1st DCA 2010) (“In sum, because all the medical evidence establishes that the only contributing causes of Claimant’s need for the cervical spine fusion were occupational in nature, the JCC erred in applying the m

2013Accordingly, the order on appeal is reversed and this case is remanded for entry of an order authorizing the surgical spine fusion.”); see also Caputo v. ABC Fine Wine & Spirits, 93 So.3d 1097, 1098 (Fla. 1st DCA 2012) (stating if “ ‘there was only one cause of claimant’s injuries, rather than competing causes, claimant was not required to present additional evidence going to the issue of whether the work-related accident was the major contributing cause of the injuries.’ ” (quoting Lanham, 868 So.2d at 563 )).

2010See Pizza Hut v. Proctor, 955 So.2d 637 (Fla. 1st DCA 2007); Pearson v. Paradise Ford, 951 So.2d 12, 17 (Fla. 1st DCA 2007) (stating “it seems evident that the legislature intended [440.09](1)(b) to apply only when the claimant’s need for treatment or benefits is caused by the impact of an employment accident combining with a preexisting injury or condition that is unrelated to an employment accident”).

2007As explained in Pearson v. Paradise Ford, 951 So.2d 12 , (Fla. 1st DCA 2007), section 440.09(1)(b) applies when a claimant's need for treatment or benefits is caused by the impact of an industrial accident combining with a preexisting injury or condition which is unrelated to an industrial accident.

2012See Caputo, 93 So.3d at 1097 ; see also Walker, 95 So.3d at 943 .

2010See Pizza Hut v. Proctor, 955 So.2d 637 (Fla. 1st DCA 2007); Pearson v. Paradise Ford, 951 So.2d 12, 17 (Fla. 1st DCA 2007) (stating “it seems evident that the legislature intended [440.09](1)(b) to apply only when the claimant’s need for treatment or benefits is caused by the impact of an employment accident combining with a preexisting injury or condition that is unrelated to an employment accident”).