Michael Caputo v. ABC Fine Wine and Spirits/Alternative Service Concepts, Inc.-First District Court of Appeals
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After Michael Caputo suffered a closed-head injury resulting from a fall from atop a ladder at work, the Judge of Compensation Claims (JCC) that heard his case determined him ineligible for workers’ compensation because the injury was idiopathic. According to the First District Court of Appeals, the JCC wrongly determined that Caputo was required to prove that his job involved exertion beyond that which he performed in his daily life.
Caputo, employed as an electrician, fell and hit his head on the floor of his employer’s facility while performing construction-related labor in the normal course of his job. He was subsequently diagnosed with a left temporal hemorrhage, a seizure disorder possibly secondary to the temporal hemorrhage, and toxic encephalopathy secondary to the temporal hemorrhage.
According to Florida case law, two factors must be proved in conjunction for a person to be eligible for workers’ compensation: “(1) the work must have been performed in the course and scope of employment, and (2) the work must be the major contributing cause of the accident or injury.” 868 So. 2d at 562-63 (citing Vigliotti v. K-mart Corp., 680 So. 2d 466, 467-68 (Fla. 1st DCA 1996)).
Although there was no question as to whether the accident occurred while Caputo was at work, the Employer/Carrier (E/C) denied the claim with the opinion that the fall resulted from a pre-existing medical or idiopathic condition.
Although medical records showed that Caputo fell in the shower approximately two years before his accident at work, the E/C failed to prove that any condition resulting from that fall, namely seizures, was a major contributing factor to the accident in question.
However, the JCC ruled that Caputo’s claim was not compensable because his fall occurred at work by chance-his job required no more exertion than his daily life. In other words, the fall could just have easily occurred when he was not at work.
The First District Court of Appeals disagreed with the JCC’s interpretation of the legal test as to whether an injury is compensable. Caputo’s fall occurred at work while he performed the normal requirements of his job. The accident resulted from his presence on the ladder while doing his job. Therefore, the First District Court of Appeals reversed the summary judgment entered by the JCC.
If your workers’ compensation claim has been denied, it is important to speak with an experienced personal injury attorney immediately. Even an unfavorable court judgment may not mean that your claim is invalid.
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