Road Film Productions v. Taylor

Appellants challenge an order of the judge of compensation claims (JCC) awarding the claimant, Michael Jackson, permanent total disability (PTD) and attendant care benefits. We affirm the award of PTD benefits without further discussion. The JCC erred, however, in awarding past attendant care benefits for a six-week period in May and June 1995, when Jackson received no attendant care services. See, e.g., Ramada Inn South Airport v. Lamoureux, 578 So.2d 48, 49 (Fla. 1st DCA 1991) (“[I]t is improper to order payment for past attendant care based solely upon the claimant’s need for care, and…