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Santos v. K-MART

Citations: 629 So. 2d 1071; 1994 WL 1896Docket: 92-2468

Court: District Court of Appeal of Florida; January 5, 1994; Florida; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a claimant in a workers' compensation matter concerning the calculation of permanent total disability benefits and the application of a social security offset. The claimant filed for a correction of benefits, asserting a miscalculation in the weekly amount received. The employer/carrier claimed an offset due to social security benefits, reducing the claimant's weekly compensation. The judge of compensation claims dismissed the claim as moot, suggesting that the claimant was already receiving more than requested. However, the appellate court found this dismissal premature, emphasizing the employee's right to judicial review of such offsets and the employer's obligation to provide evidentiary support for the appropriateness of the offsets applied. As the employer had not substantiated the offset with evidence, the appellate court remanded the case for further proceedings, underscoring the procedural necessity for employers to demonstrate the validity of social security offsets in workers' compensation claims.

Legal Issues Addressed

Burden of Proof for Social Security Offsets

Application: The appellate court emphasized that the burden of proof lies with the employer to substantiate the appropriateness of any social security offset taken in workers' compensation cases.

Reasoning: The court emphasized that the burden of proof lies with the employer to substantiate the appropriateness of any social security offset taken.

Dismissal of Claims as Moot

Application: The judge of compensation claims dismissed Santos' claim as moot because the requested amount was less than what was being paid, but the appellate court found this dismissal inappropriate due to lack of evidence supporting the offset.

Reasoning: The judge of compensation claims (JCC) dismissed Santos' claim, stating it was moot since the requested amount was less than what was being paid.

Judicial Review of Social Security Offsets in Workers' Compensation

Application: The appellate court determined that employees are entitled to judicial review of social security offsets applied by employers in workers' compensation claims.

Reasoning: The appellate court disagreed, highlighting that while employers may administratively apply social security offsets, employees are entitled to judicial review of these offsets.