Robert Bennett v. St. Vincent’s Medical Center, Inc., Respondents; Florida…

Summary

The Florida Supreme Court held that the statutory phrase “immediate postdelivery period in a hospital” must be read narrowly as a modifier of “resuscitation,” limiting NICA coverage to injuries occurring during labor, delivery, or ongoing resuscitation, and that the rebuttable presumption of compensability applies only to claimants seeking benefits under the NICA Plan. Accordingly, the Court quashed the First District’s decision and remanded for affirmation of the ALJ’s order. Justice CANADY dissented, arguing there was no express conflict and that the majority’s interpretation was dicta.