Fish v. Extreme Enterprises of Marion County, Inc., Extreme Lawn Care

District Court of Appeal of Florida·Decided August 26, 2026·No. 1D2024-2817·Published

Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA

No. 1D2024-2817

KIMBERLY FISH,

Appellant,

v.

EXTREME ENTERPRISES OF MARION COUNTY, INC. d/b/a EXTREME LAWN CARE, and AMTRUST NORTH AMERICA OF FLORIDA,

Appellees.

On appeal from the Office of the Judges of Compensation Claims. Ralph J. Humphries, Judge.

Date of Accident: July 27, 2022.

August 26, 2026

M.K. THOMAS, J.

Claimant/Guardian, Kimberly Fish, appeals an order of the Judge of Compensation Claims (JCC) denying her claim for reimbursement of expenses related to a guardianship for her son, the injured worker. Because a causal relationship existed between the compensable traumatic brain injury, which precipitated the JCC’s invocation of the provisions of section 440.17, Florida Statutes (2022), and the need for the guardianship to pursue workers’ compensation benefits, the expenses are reimbursable.

Accordingly, we set aside the JCC’s order and remand for further proceedings consistent with this opinion.

I. Facts

Claimant is the mother and now the guardian of Joseph Reed, the injured worker. 1 On July 27, 2022, Mr. Reed sustained a catastrophic brain injury because of a compensable workplace accident. He was struck by a motor vehicle while operating a “gator” vehicle to edge grass along a highway. Claimant hired a workers’ compensation attorney, Jesse Rowe, to pursue workers’ compensation benefits for her son. Attorney Rowe subsequently filed multiple petitions for benefits (PFBs) with the Office of the Judges of Compensation Claims. He later contacted the employer/carrier (E/C) requesting assistance in acquiring a guardian for the injured worker. The E/C declined.

Attorney Rowe filed a Motion to Appoint Guardian and requested that Claimant be designated as the payee on workers’ compensation checks from the E/C. After a hearing on the motion, the JCC denied the request to designate Claimant as the payee because no PFBs “are pending and, thus, no compensation awards have been or will be issued at this time, the statute does not allow for the designation of a person to receive compensation on the injured worker’s behalf.” However, he found that there was “no dispute the injured worker is incompetent.” The JCC determined that appointment of a guardian “is appropriate and necessary to receive compensation payable to the injured worker under this chapter as well as to exercise the powers granted to or perform the duties required of such person under this chapter.” Claimant was ordered to pursue by appropriate means before a court of competent jurisdiction the appointment of a guardian for the injured worker. Lastly, the JCC raised concerns whether, given

1 Following appointment of Kimberly Fish as guardian for Joseph Reed, the Judge of Compensation Claims granted an unopposed motion to substitute case parties. The order of August 14, 2024, substituted Kimberly Fish for Joseph Reed as the claimant.

that the injured worker was incompetent, “he can properly pursue claims or enter into contractual agreements to retain counsel.”

Later, additional PFBs raised pending claims, and the parties appeared at a mandatory mediation conference in February 2024. Because of the injured worker’s incapacity and the absence of a guardian, the mediation was suspended. To pursue his claims for workers’ compensation benefits and comply with the JCC’s order, Claimant retained an attorney specializing in guardianships, Sean Bogle. Attorney Bogle petitioned the circuit court for appointment of a guardian. The guardianship process required a mental health screening and that the injured worker be represented during the committee evaluations. Fees for the examining committee totaled $1,500. The filing fee for the guardianship proceeding was $414 with a separate court fee of $239.09 for the proceeding to determine incapacity.

In June 2024, the circuit judge entered an order declaring that the injured worker was totally incapacitated and appointed Claimant as his guardian. Attorney Rowe then filed a PFB seeking reimbursement of the expenses of the guardianship proceedings and a claim for attorney’s fees and costs under chapter 440, Florida Statutes.

Once Claimant was appointed as guardian, the workers’

compensation case could proceed, mediation was reconvened, and most of the outstanding claims were resolved. Regarding the claim for reimbursement of the expenses of the guardianship, the E/C denied responsibility, arguing that the JCC did not have jurisdiction to address reimbursement of guardianship costs. The parties proceeded to final hearing on the issues of reimbursement of the guardianship expenses and a claim for attorney’s fees and costs for litigation of entitlement to the reimbursement.

The JCC issued a final order denying the claims for reimbursement ($2,428.09 for the guardianship proceedings and $10,500.00 for payment of Attorney Bogle’s fee for his representation in the guardianship proceedings), and the claim for fees and costs regarding litigation of the reimbursement of the expenses. The JCC determined that: (1) all services rendered by Attorney Bogle were in the guardianship proceedings and not in

the workers’ compensation proceedings; (2) there was no showing that the E/C denied any benefits; (3) there was no showing that the expenses of the guardian were in “the handling of the claimant/ward’s rights, duties, and responsibilities under Chapter 440, obtaining medical services for the claimant, and representation of the claimant and proceedings before the JCC”; and (4) there was no showing of entitlement to attorney’s fees and costs associated with the PFBs at issue. After denial of a motion for rehearing, Claimant timely appealed.

II. Analysis

“To the extent an issue turns on resolution of the facts, our review standard is CSE; to the extent it involves an interpretation of law, the standard is de novo.” Sullivan v. NUC02, LLC/Broadspire, 308 So. 3d 659, 662 (Fla. 1st DCA 2020) (citing Benniefield v. City of Lakeland, 109 So. 3d 1288, 1290 (Fla. 1st DCA 2013)).

A JCC has an “obligation to ensure that the interests of a mentally incompetent claimant are protected.” Se. Concrete Floor v. Charlton, 584 So. 2d 574, 576 (Fla. 1st DCA 1991). A JCC errs when it neglects this obligation. See Cornelius v. Sunset Golf Course, 423 So. 2d 567, 569–70 (Fla. 1st DCA 1982); Aris v. Big Ten Taxi Corp., 330 So. 2d 465, 466 (Fla. 1976) (holding that it was error to not suspend the proceedings until a guardian had been appointed and decide the claimant’s case without any presentation on his behalf through a guardian or appointed counsel).

Section 440.17, entitled “Guardian for minor or incompetent,”

provides as follows:

Prior to the filing of a claim, the department, and after the filing of a claim, a judge of compensation claims, may require the appointment by a court of competent jurisdiction, for any person who is mentally incompetent or a minor, of a guardian or other representative to receive compensation payable to such person under this chapter and to exercise the powers granted to or to perform the duties required of such person under this chapter; however, the judge of compensation claims, in

the judge of compensation claims’ discretion, may designate in the compensation award a person to whom payment of compensation may be paid for a minor or incompetent, in which event payment to such designated person shall discharge all liability for such compensation.

While under the statute JCCs have a duty to protect the interests of an incompetent person by ordering appointment of a guardian, a JCC lacks the jurisdiction to make the appointment. Instead, jurisdiction lies in the circuit court. See § 744.102(5), Fla. Stat. (2022). Thus, if a JCC determines that a claimant is incompetent, proceedings under chapter 440 are halted pending guardianship evaluation and appointment of a guardian, if required.

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Fish v. Extreme Enterprises of Marion County, Inc., Extreme Lawn Care, (Fla. Ct. App. 2026).

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Southeastern Concrete Floor v. Charlton
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Cornelius v. Sunset Golf Course
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922 So. 2d 252 (District Court of Appeal of Florida, 2006)
Aris v. Big Ten Taxi Corporation
330 So. 2d 465 (Supreme Court of Florida, 1976)
Benniefield v. City of Lakeland
109 So. 3d 1288 (District Court of Appeal of Florida, 2013)
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