There was ample excitement in Florida workers' compensation in April. On April 20, 2016 the Florida First District Court of Appeal decided Miles v. City of Edgewater Police. On April 28, 2016, not to be outdone, the Florida Supreme Court decided Castellanos v. Next Door Company. Both are interesting and intriguing decisions. The landscape of claimant attorney fees in Florida workers' compensation is different today than it was in March.
With the excitement and furor over Castellanos, many (me initially) missed the Supreme Court's decision in Stahl v. Hialeah Hospital. Stahl was a challenge to the constitutionality of the state workers' compensation law, and specifically to exclusive remedy. It had similarities to the Padgett v. Florida Workers Advocates that was decided by the Florida Third District last year, a case which the Florida Supreme Court declined to hear.
The Supreme Court decision in Stahl is not nearly as long as Castellanos (55 pages) and really adds little to the great workers' compensation debate. Essentially, the Supreme Court said that accepted jurisdiction to hear Stahl, considered the briefs in Stahl, heard oral arguments, and has now decided not to consider the case. This is known as a "discharge" of jurisdiction. It is not a decision on the merits of the case, but a decision by the high court not to review the merits after all. The result is that the decision of the First District Court in Stahl stands, exclusive remedy in Florida stands, for now.
Stay tuned for further challenges and arguments. We still await the Supreme Court decision in Westphal, but much of the wait and conjecture is now concluded with Stahl and Castellanos decided. While many lament that the decisions were not all made yesterday, as Meatloaf reminded us "two our of three ain't bad."
The ingenuity and intelligence of the professionals engaged in the practice of Florida workers' compensation law on both sides of the debate are simply without equal.
