Background
Willie Brookins sustained a workplace injury on January 12, 2022, giving rise to a workers’ compensation claim against his employer, the Palm Beach Sheriff’s Office, and its carrier/servicing agent USIS. The matter was heard before Judge of Compensation Claims Kimberly A. Hill in the Office of the Judges of Compensation Claims.
The Palm Beach Sheriff’s Office and USIS appealed Judge Hill’s ruling to the Florida First District Court of Appeal, which has jurisdiction over workers’ compensation appeals in Florida.
The Court’s Holding
The First District Court of Appeal affirmed the decision of the Judge of Compensation Claims in a per curiam opinion. Chief Judge Osterhaus and Judges Lewis and Winokur concurred in the affirmance without further written elaboration.
The court’s one-word disposition — “AFFIRMED” — indicates the appellate panel found no reversible error in the underlying ruling by Judge Hill and that the decision below will stand.
Key Takeaways
- The First DCA affirmed the JCC’s ruling in favor of claimant Willie Brookins arising from a January 12, 2022 workplace injury.
- The per curiam affirmance without written opinion signals the appellate court found no legal error warranting reversal or discussion.
- The decision is not yet final and may be subject to further proceedings if a timely motion is filed under Florida Rules of Appellate Procedure 9.330 or 9.331.
Why It Matters
Although the First DCA issued no written opinion explaining its reasoning, the affirmance signals that the JCC’s handling of this workers’ compensation claim withstood appellate scrutiny. For practitioners, per curiam affirmances in workers’ compensation cases serve as reminders that appellate courts give significant deference to factual findings and credibility determinations made by Judges of Compensation Claims.
For law enforcement employers and their carriers, the outcome underscores the importance of thorough preparation at the JCC level, as reversals on appeal in workers’ compensation matters without a written opinion from below can be difficult to obtain.