NEW HOPE BAPTIST CHURCH v. Duran

In this workers’ compensation case, the Employer/Carrier (E/C) appeals an order of the Judge of Compensation Claims (JCC) ruling it owes interest on a late-paid installment of indemnity benefits. For the reasons below, we modify the JCC’s order.

The parties agree that a payment due on December 26, 2008, was not paid until December 29, 2008. The parties also agree that the amount of interest due on the late payment is five dollars. See § 440.20(8)(a), Fla. Stat. (2007). The record indicates, and the parties agree, that the E/C overpaid that indemnity installment by more than five dollars. The…