Reynolds v. COMMERCIAL CARRIER CORPORATION

In this workers’ compensation case, Claimant appeals an order of the Judge of Compensation Claims (JCC) awarding prevailing party costs to the Employer/Carrier (E/C). Claimant is entitled to relief. Specifically, prior to the 2003 amendment to section 440.34(3), Florida Statutes, only a prevailing claimant was permitted to tax “reasonable costs” against an E/C, whereas since that time any prevailing party may recover costs. See Ch. 03-412, § 26, at 3944, Laws of Fla. Here, it is not disputed that the accident happened in 1996, before the amendment took effect. Because the right to costs is…