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).
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