The Judges of Compensation Claims' Application Of Sedgwick CMS vs. Valcourt-Williams
William H. Rogner
he First DCA issued its en banc opinion in Sedgwick CMS v. Valcourt-Williams in 2019. Often referred to as the “dog” case, it applies far more broadly. In essence, the case established a clear test for determining whether an injury arises from the claimant’s employment. Specifically, it requires the claimant to prove that the injury was caused by an employment-created risk, which is not present in the claimant’s nonemployment life.
Since then, the JCCs have ruled on 23 ...
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