DANIEL MEADOWS, PETITIONER, CROSS-RESPONDENT,
v.
CURLY'S TRASH SERVICE, INC., MARYLAND CASUALTY COMPANY AND THE INDUSTRIAL RELATIONS COMMISSION, RESPONDENTS, CROSS-PETITIONER
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The Florida Supreme Court reviewed the Industrial Relations Commission's reversal of a workmen's compensation award to claimant Meadows for heart failure allegedly precipitated by a workplace accident. The Court held that the Commission improperly disregarded competent substantial evidence supporting the causal relationship between the accident and the claimant's heart failure, and reinstated the claims judge's award.
The Court held that the Commission abused its discretion by departing from its proper appellate role and disregarding competent substantial evidence supporting the claims judge's findings. The claims judge, as the sole trier of fact, has factual findings that are binding on the Commission when supported by competent substantial evidence.
[1] An administrative appellate tribunal departs from its proper role when it ignores competent substantial evidence supporting a fact-finder's determination.
[2] A fact-finder's findings are binding upon an administrative appellate tribunal if supported by competent substantial evidence.
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Join FLexlaw to unlock all legal intelligence“Well, it would appear from the course of events that this accident actually precipitated his heart failure. Based on the setting of hypertension and some increase in heart size prior to this relates to his long standing hypertension, but I would have to assume he had no evidence of congestive heart failure prior to this because he had been working every day and had no difficulty.”
Medical testimony establishing the causal relationship between the accident and heart failure that the Commission improperly disregarded
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Join FLexlaw to unlock all legal intelligenceMeadows suffered a workplace accident while employed by Curly's Trash Service. Medical testimony indicated the accident precipitated his congestive he…
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This is a petition for a writ of certiorari to the Industrial Relations Commission to review an order of that agency which reversed a workmen’s compensation order entered in favor of claimant-petitioner by the Judge of Industrial Claims.
The Commission’s order of reversal rests on its determination that “ * * * there is no competent substantial evidence to support the judge’s finding that there is a causal relationship between the claimant’s heart failure and his employment”.
That the Commission departed from its proper role as an administrative appellate tribunal is amply, if tersely, demonstrated by the following single response to a question as to the connection between the subject accident and claimant’s congestive heart failure which was put to a medical witness called by claimant, viz:
“A. Well, it would appear from the course of events that this accident actually precipitated his heart failure. Based on the setting of hypertension and some increase in heart size prior to this relates to his long standing hypertension, but I would have to assume he had no evidence of congestive heart failure prior to this because he had been working every day and had no difficulty.”
The above is the “competent substantial evidence” which the Commission majority chose to ignore in total disregard of this court’s frequent rulings. The following excerpt from our opinion in Painter v. Board of Public Instruction of Dade County, 223 So.2d 33, 34 is particularly appro*418priate to the Commission’s departure from its role in these cases:
“Once again the Full Commission has clearly departed from its proper function in reviewing Compensation Orders and has clearly invaded the authority of the fact finder. In recent months we have repeatedly reversed Orders of the Full Commission for this reason and have carefully and meticulously pointed out that the Deputy Commissioner is the sole trier of fact and that his findings are binding upon the Full Commission when they are supported by competent substantial evidence * * * ”
Review of the evidence adduced before the trial judge convinces us that his findings and order were supported by competent substantial evidence.
Accordingly, the order of the Commission reviewed herein is quashed and the order of the claims judge is reinstated.
We have directed our attention to respondents’ cross-petition for writ of cer-tiorari and find the same to be without merit and the same is accordingly denied.
ERVIN, Acting C. J., and ADKINS, BOYD and DREW (Retired), JJ., concur.
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S. Convalescent Home & R. P. Hewitt & Assocs. v. Wilson, 285 So. 2d 404 (Fla. 1973)…substantial evidence, the appellate tribunal will not weigh the evidence and substitute its findings for those of the trial judge. United States Casualty Co. v. Maryland Casualty Co., 55 So. 2d 741 (Fla.1951), Meadows v. Curly’s Trash Service, Inc., 244 So. 2d 417 (Fla.1971). Review of the evidence adduced before the Judge of Industrial Claims convinces us that his findings and order are supported by competent substantial evidence. Accordingly, certiorari is granted and the order of the Commission is quashed…
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Riddle v. Brevard Cnty. Bd. OF Pub. Instruction, 286 So. 2d 557 (Fla. 1973)…as to causation. (Emphasis supplied.) The test, however, is not whether there is any “clear and convincing” evidence, but whether there is any competent and substantial evidence to support the Judge’s finding. Meadows v. Curly’s Trash Service, Inc., 244 So. 2d 417 (Fla.1971). In this case, there was such competent and substantial /evidence. The testimony of both doctors, while far from conclusive, indicated that the injury could have been caused by the accident. The petitioner’s own testimony regarding the de…
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McMANNIS v. Mad-Ray Modulars, Inc., 289 So. 2d 715 (Fla. 1974)…instructions to reinstate the November 27, 1972 Order of the Judge of the Industrial Claims awarding claimant permanent total disability. It is so ordered. CARLTON, C. J., and ERVIN, Mc-CAIN and DEKLE, JJ., concur. . 279 So. 2d 281 (Fla.1973). . 244 So. 2d 417 (Fla.1971). . 223 So. 2d 33 (Fla.1969). . 55 So. 2d 741 (Fla.1951). . 265 So. 2d 8 (Fla.1972). . 251 So. 2d 260 (Fla.1971). . 234 So. 2d 99 (Fla.1970). . 120 So. 2d 596 (Fla.1960).…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Painter v. Bd. OF Pub. Instruction OF Dade Cnty., 223 So. 2d 33 (Fla. 1969)