Put it in Practice: Monthly Tips for Florida WC Professionals

Case Law Updates

(9-15-21) Florida’s 2019 Valcourt-Williams decision established a clear test for determining whether an injury arises from the claimant’s employment. Since then, claimants have prevailed in 65 percent of cases citing this blockbuster en banc decision.


  • A Valcourt-Williams denial is most likely to prevail where there is clearly a personal, non-work-related cause for an injury that occurs at work. 
  • There is substantial support for a Valcourt-Williams denial when the claimant is injured while merely walking on a defect-free surface. 
  • Whether the claimant twists an ankle, feels a knee pop or falls to the ground, a number of JCCs have been convinced that such claims no longer arise from the employment under Valcourt-Williams.

For a more detailed review of decisions driving denials where the E/C prevails, click here:


The firm will continue to monitor all these cases before the JCCs and the appellate courts and will welcome the opportunity to discuss specific facts patterns with you. 

This month’s author is Bill Rogner.  Questions?  wrogner@hrlawflorida.com