FL 4th: Intentional Harm Precludes Immunity

The Fourth District of the Florida Court of Appeals ruled that immunity does not apply to an employer/carrier's intentionally harmful actions. In Protegrity Servs., Inc. v. Vaccaro, No. 4D04-2210, 08/24/2005, Julie Vaccaro was injured and disabled in a compensable accident, and, subsequently, received benefits. For years after her accident, Vaccaro received medically necessary massage therapy, which she could not afford on her own. Nine years after her accident, Protegrity Services, Inc. (Protegrity) conducted a "utilization review" and determined that the massage therapy was not medicall...