Williams v. State, Department of Corrections

The Judge of Compensation Claims correctly found that the employer/carrier was entitled to the benefit of the workers’ compensation statute of limitations. Although the employer/carrier made certain medical and indemnity payments after the expiration of the statute, the evidence is uncon-troverted that these payments were made mistakenly. Cf. Cole v. Fairfield Cmtys., 908 So.2d 1105 (Fla. 1st DCA 2005) (finding that employer/carrier did not waive its right to deny compensability pursuant to section 440.20(4), Florida Statutes, even though employer/carrier mistakenly tendered a payment to the…