Vincent Sansone v. Frank Crum/Frank Winston Crum Insurance, Inc.

This appeal is about attorney’s fees. Under section 440.34(3)(b), Florida Statutes (2014), successful claimants can recover attorney’s fees from a carrier or employer in certain circumstances. But the statute includes a grace period, providing that “attorney’s fees shall not attach” until thirty days after the carrier or employer receives the petition for benefits. The question we address is what happens if the carrier or employer accepts responsibility for medical expenses within thirty days but does not actually pay the medical bills until after thirty days. We hold that so long as the…