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Poole & Kent Co. v. Rhea

Citations: 488 So. 2d 908; 11 Fla. L. Weekly 1191; 1986 Fla. App. LEXIS 8010Docket: No. BH-393

Court: District Court of Appeal of Florida; May 22, 1986; Florida; State Appellate Court

Narrative Opinion Summary

The court affirmed in part and reversed in part the decision of the deputy commissioner regarding the award of $70,800 in attorney’s fees to the claimant in a workers’ compensation case. The employer and carrier (E/C) contested the calculation of benefits valued at $467,000 that the attorney secured for the claimant. The court agreed with the E/C that $16,983 in past due compensation should not be included in the attorney's fee calculation, as some of this amount was paid to the claimant prior to the attorney's involvement, and thus does not qualify as benefits secured by the attorney under section 440.34, Florida Statutes. The court found the remaining calculations by the deputy commissioner to be reasonable and supported by evidence. The case was remanded for recalculation of the attorney's fee excluding the disputed past due compensation amount. Judges Smith and Wigginton concurred with the decision.

Legal Issues Addressed

Calculation of Attorney's Fees under Section 440.34, Florida Statutes

Application: The court determined that attorney's fees should not include compensation amounts that were paid to the claimant before the attorney's involvement, as these do not qualify as benefits secured by the attorney.

Reasoning: The court agreed with the E/C that $16,983 in past due compensation should not be included in the attorney's fee calculation, as some of this amount was paid to the claimant prior to the attorney's involvement, and thus does not qualify as benefits secured by the attorney under section 440.34, Florida Statutes.

Judicial Review of Deputy Commissioner's Decision

Application: The court affirmed parts of the deputy commissioner's decision, finding the calculations to be reasonable and supported by evidence, but reversed the portion concerning the inclusion of certain past due compensation in the attorney's fee calculation.

Reasoning: The court found the remaining calculations by the deputy commissioner to be reasonable and supported by evidence.

Remand for Recalculation

Application: The case was remanded to the lower authority to recalculate the attorney's fee, excluding the disputed past due compensation amount.

Reasoning: The case was remanded for recalculation of the attorney's fee excluding the disputed past due compensation amount.