Florida Forest & Park Service v. Eston Strickland

Summary

The Florida Supreme Court affirmed a circuit court judgment awarding workers' compensation to Eston Strickland, a fire-tower watchman who was injured in a gunfight with another forestry worker. The court held that a later decision changing the procedure for reviewing deputy commissioners' orders applied prospectively because Strickland had relied in good faith on the prior judicially approved procedure. On the merits, the court concluded that the appellants had not shown that the circuit court's finding in Strickland's favor was unsupported by the record.

Holdings

1. As applied to Strickland's case, Tigertail Quarries, Inc. v. Ward operated prospectively only. A claimant who proceeded in reliance on the then-prevailing judicial construction of the workers' compensation statutes could not have that procedure and potentially valuable compensation right defeated by a later overruling decision.
2. The employer and carrier failed to show that the circuit court reached an erroneous conclusion unsupported by the record; the circuit court judgment reversing the deputy commissioner was affirmed.

Questions Presented

1. Whether the circuit court had authority to review the deputy commissioner's order directly despite the intervening decision in Tigertail Quarries, Inc. v. Ward.
2. Whether Tigertail Quarries, Inc. v. Ward should operate prospectively rather than retrospectively where the claimant relied on the prior judicially approved appellate procedure.
3. Whether the employer and carrier demonstrated that the circuit court's reversal of the deputy commissioner's denial of compensation was unsupported by the record.

Disposition

affirmed