JCC Denies Claim for Break-Room Baby Shower Fall

In Brown v. Tampa Family Health Centers / CCMSI, OJCC Case No. 25-006283MAM, Judge Mark A. Massey addressed whether a fall during an unpaid lunch break arose out of employment.

The claimant clocked out, went to the employer's break room, fixed a plate at a co-worker's baby shower, and tripped over a chair while walking to sit down. The JCC found the shower was not employer-sponsored, attendance was not required, and the claimant was not performing work or on call.

Applying section 440.092(1), Florida Statutes, the JCC treated the shower as a social activity unrelated to employment. The petition seeking compensability, medical care, indemnity benefits, penalties, interest, costs, and attorney's fees was denied and dismissed with prejudice.

Source: Compensation Order