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Sixth District Court of Appeals Says Fourth District Got It Wrong: Florida’s Pre-Suit Notice Requirement Does Not Apply Retroactively

In November 2023, the Sixth District Court of Appeal of Florida, in direct conflict with the Fourth District Court of Appeal of Florida, found that the pre-suit notice as mandated by Florida Statute 627.70152 does not apply retroa Legal Update for Insurance Services, January 8, 2024, has been prepared for our readers by Marshall Dennehey.

Superior Court affirms decision that claimant failed to prove she contracted COVID-19 at work, but does not reach issue of whether COVID-19 qualifies as an occupational disease for a nurse who worked in the “COVID wing” of a hospital.

Ms. Hudson worked as a front-line nurse for the employer on its COVID-19 floor in the Fall of 2020. She contracted COVID at some point in October 2020 and was hospitalized on October 21, 2020. Her sons contracted the virus at the same time. What’s Hot in Workers’ Comp, Vol. 28, No.

Appellate Division affirmed the workers’ compensation judge’s orders, granting the petitioner’s application for Temporary Total Disability benefits and denying respondent’s Request for Reconsideration.

The petitioner was injured in 2018 and resolved her case for 25% partial-total disability in 2021. In 2018, she had returned to work for Complete Care as a certified nursing assistant and, in 2019, as a home health aide for Interim Agency. What’s Hot in Workers’ Comp, Vol. 28, No.