In Edmond v. Avis Budget Group, Inc., a rental car company worker sought workers’ compensation benefits payments after he was hurt at work in Florida. According to the employee, he was rendered temporarily disabled as a result of the workplace accident. Following a workers’ compensation hearing, a Judge of Compensation Claims (“JCC”) ordered the rental car business to pay the injured man more than $1,300 in temporary disability benefits and about $267.00 in legal fees. After that, the hurt worker filed an appeal with Florida’s First District Court of Appeal.
On appeal, the employee raised two constitutional claims and argued the JCC committed error by failing to issue an award for reasonable attorney’s fees for the work performed by his counsel in order to demonstrate the man’s entitlement to legal fees under Section 440.34 of the Florida Statutes. After filing his appeal, the court requested that the worker show cause why the court’s 2013 decision in another case was not controlling. Next, the employee admitted the case at issue controlled his two constitutional claims. The First District then turned to the man’s inadequate legal fees, or “fees on fees,” argument.