JCC Denies Head-Treatment Claim and Predicate Compensability Rulings

In Amber Jamrock v. Publix Super Markets Inc./Publix Risk Management and The Hartford, OJCC Case No. 25-024024BKC, Judge Barbara K. Case addressed petitions seeking acceptance of additional conditions after a March 20, 2024 fall from a step ladder. The employer/carrier had accepted the accident, the right foot, right ankle, right lower extremity, psychiatric issues, and CRPS, and the claimant continued receiving authorized treatment for the accepted lower-extremity conditions.

The JCC found the requests for adjudication of CRPS II and balance issues were not proper standalone benefit claims. Because the claimant was seeking predicate rulings for potential future benefits rather than a ripe medical or indemnity benefit, the order concluded the JCC lacked jurisdiction to substantively decide those compensability questions.

The only ripe medical claim was for authorization and scheduling of a primary care physician for an alleged head injury. That claim was denied because the claimant reported hitting her head but had a normal CT scan, no diagnosis, no symptoms requiring treatment, and no medical recommendation tying head treatment to the industrial accident; fees and costs were also denied.

Source: Compensation Order