JUANITA REDDING, PETITIONER,
v.
COBIA BOAT CO., RESPONDENT
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Juanita Redding, a boat interior installer, suffered severe burns from a workplace fire and sought workers' compensation temporary total disability benefits. The Florida Supreme Court reversed the Industrial Relations Commission's reversal of the judge's award, holding that substantial evidence supported finding Redding unable to return to work due to legitimate psychiatric concerns stemming from her injury.
The IRC's reversal departed from the essential requirements of law because the JIC's award of temporary total disability benefits was supported by competent substantial evidence, including the claimant's psychiatric condition and genuine fear of returning to work. When psychiatric problems are involved, the JIC's opportunity to observe the claimant and weigh subjective factors is crucial, and appellate courts must not reweigh evidence but only determine if substantial evidence supports the award.
[1] An appellate court departs from the essential requirements of law when it reverses a workers' compensation order that is supported by competent substantial evidence.
[2] When reviewing workers' compensation cases for factual sufficiency, appellate courts must determine only if the judge of industrial claims' order is supported by competen…
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Join FLexlaw to unlock all legal intelligence“When psychiatric problems are involved, the JIC's opportunity to view a claimant and to weigh subjective factors impeding the capacity to return to gainful employment must be kept in mind when determining the correctness of an award.”
Establishes the special deference due to trial-level judges when psychiatric factors affect disability determinations.
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Join FLexlaw to unlock all legal intelligenceRedding worked for Cobia Boat Co. for eight years installing vinyl interiors. In March 1977, a flash fire caused by flammable glue ignited and burned …
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McDONALD, Justice.
We have before us a petition for certiorari to review an order of the Industrial Relations Commission reversing the order of a judge of industrial claims. We have jurisdiction. Art. V, § 3(b)(3), Fla.Const. (1972). We find that the IRC departed from the essential requirements of law and, therefore, reverse.
Redding installed vinyl interiors in boats manufactured by Cobia and had been employed by that company for eight years. In March 1977 a flash fire ignited highly flammable glue used in the installation process and caused first-and second-degree burns to Redding’s face, neck, and arms. In January 1978 a JIC ordered that Redding be paid temporary total disability benefits and that she be furnished further medical and psychiatric treatment as needed. At a subsequent hearing in June 1978 the JIC awarded continuing temporary total benefits, finding that Redding was genuinely afraid of returning to work for Cobia and that she had made a bona fide effort to find other employment. After reviewing the record, two IRC commissioners concluded that the order was not supported by competent substantial evidence and reversed. Cobia Boat Co. v. Redding, IRC Order 2-3795 (Apr. 25, 1979).
After completing our own review of the record we agree with Commissioner Carroll’s conclusion (in dissent) that competent substantial evidence supported the JIC’s order. In his testimony Redding’s psychiatrist stated that, although he recommended that she seek part-time employment, he did not know how Redding would tolerate returning to work and that, in any case, she would need at least three to six months of additional psychiatric care. Redding had been offered several part-time jobs at Co-bia, but testified that she was afraid-because of her previous injury there-to return to the boat company. She also testified as to her efforts to find other employment.
When psychiatric problems are involved, the JIC’s opportunity to view a claimant and to weigh subjective factors impeding the capacity to return to gainful employment must be kept in mind when determining the correctness of an award. In reviewing workmen’s compensation cases for factual sufficiency, it is the duty of both this Court and of the IRC to determine only if a JIC’s order is supported by competent substantial evidence; reweighing the evidence is not a proper function. Howard v. Green’s Tractor Co., 290 So. 2d 46 (Fla.1973).
We find the JIC’s award of temporary total disability benefits adequately supported by the record on the facts of this case and that, by reversing that award, the IRC departed from the essential requirements of law. Accordingly, the IRC order is quashed, and the order of the JIC is reinstated.
It is so ordered.
SUNDBERG, C. J., and ADKINS, BOYD and OVERTON, JJ., concur. ENGLAND and ALDERMAN, JJ., dissent.
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Swanigan v. Dobbs House & Am. Motorists Ins. Co., 442 So. 2d 1026 (Fla. 1st DCA 1983)…ent for that of the deputy on factual issues supported by competent, substantial evidence, and appeals asking us to do so are frivolous. Catron Beverages, Inc. v. Maynard, 395 So. 2d 261, 262 (Fla. 1st DCA 1981). See also, Redding v. Cobia Boat Co., 389 So. 2d 1003, 1004 (Fla.1980); Croft v. Pinkerton-Hayes Lumber Co., 386 So. 2d 535, 536 (Fla.1980). We suggest that a convenient and practical means for avoiding this common error is to state, at the outset of each point argued, the legal standard for appellate…
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Sanlando Util. Corp. & U. S. Fid. & Guar. Co. v. Morris, 418 So. 2d 389 (Fla. 1st DCA 1982)…ence, we recognize that factual determinations by a deputy commissioner are normally1 not to be reweighed by an appellate tribunal even though substantial evidence may be mar-shalled to counter the deputy’s determinations. Redding v. Cobia Boat Co., 389 So. 2d 1003, 1004 (Fla.1980); Croft v. Pinkerton-Hayes Lumber Co., 386 So. 2d 535, 536-537 (Fla.1980). However, this rule evaporates when, as here, there is no competent evidence to support a deputy’s conclusions. We think this case is factually similar to Gil…
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Arand Constr. Co. v. Duford Dyer, 592 So. 2d 276 (Fla. 1st DCA 1991)…ent. From the JCC’s order, this appeal is taken. The function of a reviewing court is to determine whether the JCC’s order is supported by competent substantial evidence; reweighing the evidence is not a proper function. Redding v. Cobia Boat Co., 389 So. 2d 1003 (Fla.1980). If competent substantial evidence supports the JCC then it is irrelevant that there is also competent substantial evidence to support a contrary finding. Conshor, Inc. v. Roberts, 498 So. 2d 622, 623 (Fla. 1st DCA 1986). Despite the app…
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- Howard v. Green's Tractor Co., 290 So. 2d 46 (Fla. 1973)