CARRIUS WILLIAMS, APPELLANT,
v.
STATE OF FLORIDA, DEPARTMENT OF CORRECTIONS AND FLORIDA DEPARTMENT OF FINANCIAL SERVICES, DIVISION OF RISK MANAGEMENT, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Employer/carrier's mistaken post-limitations payments do not waive the workers' compensation statute of limitations, and employee cannot invoke estoppel without showing detrimental reliance.
An employer/carrier does not waive its right to assert the workers' compensation statute of limitations merely by making mistaken medical and indemnity payments after the statutory period has expired.
[1] Mistaken post-limitations payments by an employer/carrier do not constitute a waiver of the workers' compensation statute of limitations defense.
[2] Estoppel cannot be invoked to overcome a statute of limitations defense absent a showing of detrimental reliance by the claimant.
Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligenceWilliams' employer/carrier made certain medical and indemnity payments after the expiration of the workers' compensation statute of limitations, but t…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Workers' Compensation Statute Of Limitations cases and more on FLexlaw
PER CURIAM.
The Judge of Compensation Claims correctly found that the employer/carrier was entitled to the benefit of the workers’ compensation statute of limitations. Although the employer/carrier made certain medical and indemnity payments after the expiration of the statute, the evidence is uncon-troverted that these payments were made mistakenly. Cf. Cole v. Fairfield Cmtys., 908 So. 2d 1105 (Fla. 1st DCA 2005) (finding that employer/carrier did not waive its right to deny compensability pursuant to section 440.20(4), Florida Statutes, even though employer/carrier mistakenly tendered a payment to the medical provider). Although appellant Williams was blameless in his employer’s mistaken payments, he is nevertheless not entitled to invoke the doctrine of estoppel in order to avoid the statute of limitations because he cannot show that he has detrimentally changed his position as a result of the employer/carrier’s mistake. See Adamides v. City of Miami, 885 So. 2d 955, 957 n. 4 (Fla. 1st DCA 2004); see also Mandarin Paint & Flooring, Inc. v. Potura Coatings of Jacksonville, Inc., 744 So. 2d 482, 485 (Fla. 1st DCA 1999)(holding that detrimental reliance is necessary for estoppel).
AFFIRMED.
KAHN, C.J., BARFIELD and DAVIS, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Mandarin Paint & Flooring, Inc. v. Potura Coatings OF Jacksonville, Inc., 744 So. 2d 482 (Fla. 1st DCA 1999)
- Cole v. Fairfield Communities and Rskco, 908 So. 2d 1105 (Fla. 1st DCA 2005)
- Adamides v. City OF Miami & City of Miami Risk Mgmt., 885 So. 2d 955 (Fla. 1st DCA 2004)