Walt Disney World v. Desselles

Walt Disney World appeals the Judge of Compensation Claims’ (JCC) order which, after finding the Claimant suffered a significant change in condition, granted a modification of a prior order denying permanent total disability (PTD) benefits pur*829suant to section 440.28, Florida Statutes (2001). We affirm the award of PTD benefits. However, because there is no record evidence to support the effective date of the award, we remand for proceedings consistent with this opinion.

A party seeking a change in condition “must demonstrate by new and positive evidence that the claimant’s condition has…