PTD claim (Florida) · Go Syfert
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PTD claim in Florida

12 Florida opinions name it 1 courts 1986–2013 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 (11)

CaseFollowedCited
Burnup & Sims, Inc. v. Ozmentgreen
fladistctapp · 1983 · cited in 2 Florida opinions naming this issue, 1987–1991
2 sentences

1991See Burnup & Sims, Inc. v. Ozment, 440 So.2d 29, 32 (Fla. 1st DCA 1983) (although claimant who is PTD has a right to be accepted as PTD, the fact that E/C continues to pay TTD benefits during the pendency of investigation is relevant to the issue of whether the E/C acted reasonably in continuing to investigate a PTD claim).

1991See Burnup & Sims, Inc. v. Ozment, 440 So.2d 29, 32 (Fla. 1st DCA 1983) (although claimant who is PTD has a right to be accepted as PTD, the fact that E/C continues to pay TTD benefits during the pendency of investigation is relevant to the issue of whether the E/C acted reasonably in continuing to investigate a PTD claim).

22
Shaw v. Publix Supermarkets, Inc.green
fladistctapp · 1992 · cited in 2 Florida opinions naming this issue, 2003–2009
2 sentences

2009See id. (citing Shaw v. Publix Supermarkets, Inc., 609 So.2d 683, 686 (Fla. 1st DCA 1992)).

2009See id. (citing Shaw v. Publix Supermarkets, Inc., 609 So.2d 683, 686 (Fla. 1st DCA 1992)).

12
Daws Mfg. Co., Inc. v. Ostoyicgreen
fladistctapp · 2000 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013Co., Inc. v. Ostoyic, 756 So.2d 175, 176 (Fla. 1st DCA 2000) (noting that JCC did not have benefit of Oswald "where we explained that to establish entitlement to permanent total disability indemnity benefits under the revised version of chapter 440 which went into effect on January 1, 1994, a claimant must prove total disability on account of impairment existing after the date of maximum medical improvement [and] Ostoyic has conceded that the record on appeal does not establish ... under the exception to the ‘venerable rule’ that permanent disability benefits are premature if claimant is not y

11
Olmo v. Rehabcare Starmed/SRSgreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2010–2010
2 sentences

2010See, e.g., Olmo v. Rehabcare Starmed/SRS, 930 So.2d 789 (Fla. 1st DCA 2006) (explaining an award of PTD made before effects of treatment are known is premature).

2010See, e.g., Olmo v. Rehabcare Starmed/SRS, 930 So.2d 789 (Fla. 1st DCA 2006) (explaining an award of PTD made before effects of treatment are known is premature).

11
Wal-Mart Stores, Inc. v. Liggongreen
fladistctapp · 1996 · cited in 1 Florida opinions naming this issue, 2009–2009
2 sentences

2009See id. (citing Shaw v. Publix Supermarkets, Inc., 609 So.2d 683, 686 (Fla. 1st DCA 1992)).

2009See id. (citing Shaw v. Publix Supermarkets, Inc., 609 So.2d 683, 686 (Fla. 1st DCA 1992)).

11
Bill's Equipment and Rentals v. Teelgreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 1996–1996
1 sentence

1996Cf. Bill's Equipment and Rentals v. Teel, 498 So.2d 536, 537 (Fla. 1st DCA 1986) (deputy commissioner did not err in excusing claimant's failure to more actively seek employment where "[t]he record reveals that claimant sought employment commensurate with his work experience and job skills, while the employer made no effort to obtain employment for claimant"); Thompkins & Sons Lawn Spray v. Brooks, 452 So.2d 103, 103-04 (Fla. 1st DCA 1984) (mentally retarded claimant had permanent injury to both legs, preventing him from standing or sitting for more than hour at a time, and during two years be

11
Gatz v. Stategreen
fladistctapp · 1994 · cited in 1 Florida opinions naming this issue, 1996–1996
1 sentence

1996See, e.g., Fairchild Aircraft v. Raybon, 634 So.2d 801 (Fla. 1st DCA 1994).

11
Drummond v. Plumbing Corp. of Americagreen
fladistctapp · 1983 · cited in 1 Florida opinions naming this issue, 1996–1996
1 sentence

1996Cf. Bill's Equipment and Rentals v. Teel, 498 So.2d 536, 537 (Fla. 1st DCA 1986) (deputy commissioner did not err in excusing claimant's failure to more actively seek employment where "[t]he record reveals that claimant sought employment commensurate with his work experience and job skills, while the employer made no effort to obtain employment for claimant"); Thompkins & Sons Lawn Spray v. Brooks, 452 So.2d 103, 103-04 (Fla. 1st DCA 1984) (mentally retarded claimant had permanent injury to both legs, preventing him from standing or sitting for more than hour at a time, and during two years be

11
Thompkins & Sons Lawn Spray v. Brooksgreen
fladistctapp · 1984 · cited in 1 Florida opinions naming this issue, 1996–1996
1 sentence

1996Cf. Bill's Equipment and Rentals v. Teel, 498 So.2d 536, 537 (Fla. 1st DCA 1986) (deputy commissioner did not err in excusing claimant's failure to more actively seek employment where "[t]he record reveals that claimant sought employment commensurate with his work experience and job skills, while the employer made no effort to obtain employment for claimant"); Thompkins & Sons Lawn Spray v. Brooks, 452 So.2d 103, 103-04 (Fla. 1st DCA 1984) (mentally retarded claimant had permanent injury to both legs, preventing him from standing or sitting for more than hour at a time, and during two years be

11
Bray v. Electronic Door-Lift, Inc.green
fladistctapp · 1989 · cited in 1 Florida opinions naming this issue, 1991–1991
2 sentences

1991Bray v. Electronic Door-Lift, Inc., 558 So.2d 43, 46 (Fla. 1st DCA 1989).

1991Bray v. Electronic Door-Lift, Inc., 558 So.2d 43, 46 (Fla. 1st DCA 1989).

11
National Airlines, Inc. v. Wiklegreen
fladistctapp · 1984 · cited in 1 Florida opinions naming this issue, 1987–1987
2 sentences

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

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 (7)

CaseCitedYears
Metropolitan Title & Guar. Co. v. Muniz green
fladistctapp · 2002
1 sentence

2013Co. v. Muniz, 806 So.2d 637 (Fla. 1st DCA 2002) ("On remand, the claimant may present evidence that he has reached maximum medical improvement ... [but] if that is not the case, and if temporary benefits have expired, the claimant may obtain an impairment rating and seek permanent total disability benefits based on a future date of maximum medical improvements under the procedure in Oswald.”) (emphasis added); McDevitt Street Bovis v. Rogers, 770 So.2d 180 (Fla. 1st DCA 2000) ("nobody testified either that the claimant had reached maximum medical (psychiatric) improvement or that she would rem

12013–2013
McDevitt Street Bovis v. Rogers green
fladistctapp · 2000
1 sentence

2013Co. v. Muniz, 806 So.2d 637 (Fla. 1st DCA 2002) ("On remand, the claimant may present evidence that he has reached maximum medical improvement ... [but] if that is not the case, and if temporary benefits have expired, the claimant may obtain an impairment rating and seek permanent total disability benefits based on a future date of maximum medical improvements under the procedure in Oswald.”) (emphasis added); McDevitt Street Bovis v. Rogers, 770 So.2d 180 (Fla. 1st DCA 2000) ("nobody testified either that the claimant had reached maximum medical (psychiatric) improvement or that she would rem

12013–2013
MacEk v. State green
fladistctapp · 1982
2 sentences

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

11987–1987
G & S PACKING CO. v. Driggers green
fladistctapp · 1980
2 sentences

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

11987–1987
Smith v. Dixie Packers, Inc. green
fladistctapp · 1980
2 sentences

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

1987See National Airlines, Inc. v. Wikle, 451 So.2d 908 ; DiMuro v. Dave’s Tile Service, Inc., 409 So.2d 107 (Fla. 1st DCA 1982); Smith v. Dixie Packers, Inc., 384 So.2d 709 (Fla. 1st DCA), petition for review denied, 392 So.2d 1373 (Fla.1980); G & S Packing Co. v. Driggers, 382 So.2d 446 (Fla. 1st DCA 1980).

11987–1987
Chisholm v. McCormick, Conduit, Buckley neutral
fladistctapp · 1983
2 sentences

1987It was clearly held by this court in Chisholm v. McCormick, Conduit, Buckley, 437 So.2d 699 (Fla. 1st DCA 1983) that “[njeither statutory provisions nor the Florida Workers’ Compensation Rules preclude the deputy from hearing [a claimant’s] wage loss claim during the pendency of his appeal from the final order denying the PTD claim”.

1987It was clearly held by this court in Chisholm v. McCormick, Conduit, Buckley, 437 So.2d 699 (Fla. 1st DCA 1983) that “[njeither statutory provisions nor the Florida Workers’ Compensation Rules preclude the deputy from hearing [a claimant’s] wage loss claim during the pendency of his appeal from the final order denying the PTD claim”.

11987–1987
Escambia County Council v. Goldsmith neutral
fladistctapp · 1985
2 sentences

1986The E/C next contends that, even if the PTD award is correct, the D/C erred in failing to apportion that award pursuant to Escambia County Council on Aging v. Goldsmith, 465 So.2d 655 (Fla. 1st DCA 1985), which appeared to hold that the apportionment of permanent benefits based on a pre-existing condition does not require a showing by the E/C that the condition caused disability prior to the industrial accident, but merely impairment.

1986The E/C next contends that, even if the PTD award is correct, the D/C erred in failing to apportion that award pursuant to Escambia County Council on Aging v. Goldsmith, 465 So.2d 655 (Fla. 1st DCA 1985), which appeared to hold that the apportionment of permanent benefits based on a pre-existing condition does not require a showing by the E/C that the condition caused disability prior to the industrial accident, but merely impairment.

11986–1986

Statutes the citing opinions construe

FL § 440.15 (7) FL § 440.34 (4) FL § 440.13 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

FL 12 (1986–2013) OH 11 (2002–2017) MO 3 (2014–2021) UT 3 (2015–2024) AK 2 (1996–2021) OR 2 (1989–1999)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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