Clark v. Amazon.com Services, LLC
A pro se workers' compensation claimant's petition to be relieved of the cost of the record on appeal was denied by the JCC because her financial affidavit did not disclose her husband's full income, as required by section 440.25(5)(b) and Florida Rule of Appellate Procedure 9.180(g)(3)(D). The First DCA reversed, noting that the claimant had accurately completed every field of the OJCC's own official affidavit form, which does not solicit all marital income the statute requires, and remanded for the JCC to reconsider the totality of the circumstances.
Key facts
- Pro se workers' compensation claimant sought relief from the cost of the record on appeal based on financial hardship.
- The JCC denied the petition because the claimant's financial affidavit did not disclose her husband's full income as required by statute and appellate rule.
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Why it matters
This decision gives workers' compensation appellants a concrete argument against with-prejudice denials of cost-relief petitions where the OJCC's official form itself omits statutorily required marital income fields. It… — full analysis with a trial
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