HARBOR FREIGHT TOOLS, INC. AND SAFETY ETC.
v.
PATRICIA WHITEHEAD

Fla. 1st DCA | 2018-05-18
No. 17-3194
Florida District Court of Appeal, First District (2018)

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Holding

The 120-day rule in workers' compensation is an affirmative defense that must be timely raised and specifically pleaded.


Headnotes

[1] The 120-day rule in workers' compensation is an affirmative defense that must be timely raised and specifically pleaded in order for a compensation judge to apply it.

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Key Quotes

“affirmative pleading which must be timely raised and specifically plead[ed]”

Court stated this as the standard for the 120-day rule, citing Teco Energy, Inc. v. Williams, 234 So. 3d 816, 823 (Fla. 1st DCA 2017)

Facts & Procedural History

Harbor Freight Tools and Safety appealed a workers' compensation judge's award of benefits to claimant Patricia Whitehead. The claimant did not specif…

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Opinion of the Court

affirmative pleading which must be timely raised and specifically plead[ed].” Teco Energy, Inc. v. Williams, 234 So. 3d 816, 823 (Fla. 1st DCA 2017). Here the claimant did not specifically plead application of the 120-day rule. The judge of compensation claims therefore erred in awarding benefits based on the rule.

REVERSED.

LEWIS, KELSEY, and WINSOR, JJ., concur. _____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.

_____________________________ Daniel M. Schwarz and Gina M. Jacobs of Cole, Scott & Kissane, P.A., Plantation, for Appellants. Daniel J. Glary, Jacksonville, for Appellee.


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