Salzman v. Reyes

In this workers’ compensation case, Claimant’s former attorney appeals the Judge of Compensation Claims’ (JCC’s) order denying his verified motion for approval of a stipulated quantum meruit attorney’s fee. An appellate court’s function in reviewing the resolution of a quantum meruit lien is to determine whether the trial judge abused his or her discretion and whether the decision is based on competent, substantial evidence (CSE). See Adams v. Fisher, 390 So.2d 1248, 1251 (Fla. 1st DCA 1980). We reverse because the JCC abused her discretion when she rejected the parties’ stipulation as to…