Energy Air & Amerisure Insurance Co. v. Lalonde

In this workers’ compensation case, the Employer/Carrier (E/C) appeals an order of the Judge of Compensation Claims (JCC) finding Claimant’s heat exhaustion injury compensable and awarding past medical bills. The E/C argues that the JCC erred both in finding compensability of the heat exposure injury in the absence of evidence that Claimant “was exposed to dangers materially in excess to which the community is exposed,” and in awarding the past medical bills in the absence of evidence that they were related to Claimant’s heat exhaustion. We affirm on both points, and write solely to confirm…