Sanabria v. SPC Roofers, LLC / Southeast Personnel Leasing

JCC Anderson (Orlando) (William Rogner) (10-1-2026) – Denied increase in AWW. The claimant suffered a compensable work accident. During the 13 weeks preceding the accident, the claimant worked for two covered employers. The claimant only worked for both employers from 2/19/24 through 3/2/24. The gross earnings were $6,792.61 for the covered concurrent employer and $6,768.00 for the employer. The claimant argued that because his earnings with the employer fell below 75% a hybrid model of the statute should apply resulting in an AWW of $1,242.51. The JCC found Florida law prohibits mixing and matching statutory calculation methods to create a hybrid AWW and cited Wal-Mart Stores v. Campbell, a case that Bill won in front of the Florida Supreme Court back in 1996. The JCC denied the increase in AWW.   Click here to view Order