Santana v. American Airlines

Claimant asserts the Judge of Compensation Claims (JCC) erred by ordering her to execute and submit completed settlement documents. The parties in a workers’ compensation case may reach “a valid, binding oral settlement,” but the record must contain some evidence of the terms of the agreement. See Bonagura v. Home Depot, 991 So.2d 902, 904 (Fla. 1st DCA 2008). Here, the JCC based his orders granting Appellees’ motion to enforce settlement entirely upon an unsworn motion filed by the Employer/Carrier. This does not constitute competent substantial evidence. See O’Connor v. Hillsborough County…