Dan Beth Medical v. Snowden

Dan Beth Medical and United Self Insured Services, the employer and carrier (E/C), appeal an order of the judge of compensation claims (JCC), awarding penalties and interest to Henry Snowden, the claimant, based upon the untimely payment of settlement proceeds pursuant to section 440.20, Florida Statutes (Supp. 1994). We reverse, because claimant waived his right to seek penalties and interest by proceeding under section 631.929, Florida Statutes (1997).

Consistent with section 631.929, Snow-den sought benefits from the Florida Workers’ Compensation Insurance Guaranty Association (FWCIGA)…