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State Courts -
Florida - February 9, 2009
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Fla. Transp. 1982, Inc. v. Quintana, CASE NO. 1D08-3213,
COURT OF APPEAL OF FLORIDA, FIRST DISTRICT, February 9, 2009, Opinion Filed
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Overview: While under ? 440.15(2), (4), Fla. Stat., workers' compensation claimant could have applied for PTD based on a medical injury, a JCC erred in awarding temporary PTD on a psychiatric injury for which MMI had not been reached because the Emanuel decision that the JCC relied on did not allow for temporary PTD.
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