Gulf Management, Inc. v. Wall
The First DCA affirmed a JCC's award of permanent total disability benefits, holding that the JCC's findings were supported by competent, substantial evidence. The court took the occasion to clarify that the "three ways" to prove PTD catalogued in Blake v. Merck are not separate theories of recovery with their own elements, but non-exclusive guidelines describing forms of proof a JCC may weigh holistically under section 440.15(1)(b).
Key facts
- Gulf Management, Inc. employed Wall, a workers' compensation claimant who sought permanent total disability benefits.
- The trial court (JCC) awarded permanent total disability benefits based on medical evidence, vocational expert testimony, and job-search evidence.
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Why it matters
The opinion is the clearest statement to date that Blake's "three methods" for proving permanent total disability are evidentiary guideposts rather than discrete causes of action with mandatory elements, undercutting a… — full analysis with a trial
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