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The Shall in Workers Compensation Referral

02/16/21 Judge David Langham In 2009, Martin Leibowitz and I composed an article that The Florida Bar Workers Compensation Section was gracious to publish in its quarterly News and 440 Report. It is an overview of the complex challenges that can occur when an administrative judge finds her/himself with no further tools to deploy as regards the proceedings. Unfortunately, the Section website no longer includes that issue. A copy of The article notes that JCCs have no inherent judicial authority. Thus, the tools at a JCC s disposal are those afforded by statute. The Florida courts have been quick to remind judges of that over the decades, as noted in cases such as Millinger v. Broward County Mental Health & Risk Mgmt., 672 So.2d 24 (Fla. 1996); Pace v. Miami-Dade County Sch. Bd., 868 So.2d 1286, 1287 (Fla. 1st DCA 2004); Pruden v. Herbert Contrs., Inc., 988 So.2d 135 (Fla. 1st DCA 2008). Judges of Compensation Claims have only the authority that the statute conveys.

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