Blake devotes his practice to the defense of employers and insurance carriers in claims and appeals arising under the Florida Workers’ Compensation Act as well as claims brought under the federal Longshore and Harbor Workers’ Compensation Act.
Blake is Board Certified by The Florida Bar in Workers’ Compensation, a designation he earned in 2013. He is experienced in workers’ compensation law dealing with the analysis and litigation of problems or controversies arising out of the Florida Workers’ Compensation Law.
In addition to his practice that extends throughout the state of Florida, Blake is also licensed to practice law in North Carolina. He represents many insurance carriers and third party administrators. Additionally, he lectures on various topics concerning state and federal workers’ compensation claims.
An active member of the Jacksonville Bar Association, Blake currently serves as the co-chair of the Social Security and Workers' Compensation Law Committee. He previously served as co-chair of the Workers’ Compensation Section. Blake also proudly served as Co-Chair for the Friends of 440 Scholarship Fund between 2010 and 2012 and helped coordinate numerous fundraising events for the purpose of raising scholarship funds for the organization.
When not working, Blake enjoys spending his time with his wife and daughter, cooking, reading and playing classical guitar.
Thought Leadership
What's Hot in Workers' Comp
Workers’ Compensation Decision Clarifies that Out‑of‑State Family Visits Don’t Meet Medical Necessity Standard
June 8, 2026
Purple Pride, Inc. v. Burgess, 51 Fla. L. Weekly D479 (Fla. 1st DCA Mar. 18, 2026), reh'g denied (Mar. 31, 2026) The claimant suffered a work-related motor vehicle accident in 2019 that caused him to become tetraplegic (or quadriplegic), requiring around-the-clock attendant care. In 2024, the claimant filed a petition for benefits, requesting certain attendant care benefits he felt were necessary to allow him to take a trip to visit family in New York. The benefits he sought included the extra cost of traveling attendants, including their overtime pay and accommodations, and the extra cost of renting a Hoyer lift, commode chair, and other durable medical equipment (DME) needed for the trip. The employer/carrier denied the request as not being medically necessary. The claimant obtained an opinion from the treating psychotherapist that a visit to see family in New York would improve claimant's mental health. The psychotherapist opined that the trip was “medically necessary” in the sense that it could improve claimant's symptoms related to depression and anxiety. The Judge of Compensation Claims (JCC) rejected the claimant’s position that the trip to New York itself was medically necessary under the definition of medical necessity in § 440.13(1)(k), Fla. Stat. (2024). However, the JCC found that the employer/carrier should nonetheless be required to pay for the additional costs the claimant would incur to travel with the attendants and DMEs. In the JCC's view, the employer/carrier should cover those costs anywhere, pursuant to “the maxim that industry is responsible for what industry causes.” The First District Court of Appeal set aside the JCC’s order and held that because the JCC concluded that the claimant's trip to New York was not medically necessary, it was error to require the employer/carrier to pay for the additional medical benefits he sought for the trip. The court explained that “transportation other than to a doctor” reflects on quality of life rather than medical necessity and is “generally considered gratuitous and not compensable.” Therefore, the JCC’s order was set aside.
What's Hot in Workers' Comp
The First District Court of Appeal Adopts (Again) New Methodology for Analyzing Statute of Limitations
May 1, 2026
Estes v. Palm Beach Cnty. Sch. Dist., No. 1D2025-0079, 2026 (Fla. 1st DCA Mar. 23, 2026) The First District Court of Appeal issued another opinion in the court’s ever-developing interpretation of the statute of limitations provision of Florida Statutes Section 440.19(2). The court did so en banc, moreover, because it intended to correct the court’s interpretation of Section 440.19(2) in a way that directly conflicts with how several previous panels of the court applied the tolling provision. The Estes case clarifies that the proper methodology for determining whether the statute of limitations has run is akin to the “master timer/tolling timer” methodology of Ortiz v. Winn-Dixie, Inc., 361 So. 3d 889, 893 (Fla. 1st DCA 2023), which was superseded by Ortiz v. Winn-Dixie, Inc., 402 So. 3d 301 (Fla. 1st DCA 2024). In Estes, the petition for benefits at issue had been filed in June 2024, which was more than two years after the accident, and more than one year after the furnishment of the last compensation benefit. The Judge of Compensation Claims (JCC) followed the statute-of-limitations approach from prior cases and concluded that Section 440.19(1)’s two-year statute of limitations had lapsed after having never been suspended or abated by operation of Section 440.19(2). The court analyzed the history of Section 440.19 and noted that the 1994 statutory amendments changed the provision from an extension-based analysis to a tolling-based one. Section 440.19(1) of the post-1994 statute provides that an PFB must be filed within two years of the date when the claimant knew or should have known that the injury arose out of work performed in the course and scope of employment. Section 440.19(2) states that the provision of benefits “shall toll the limitations period set forth above for 1 year from the date of such payment.” Older cases had held that the one-year tolling period did not apply to the initial two-year period; the court in Estes clarified that it does. The court further clarified that “tolling” means to “suspend,” “stop temporarily,” or “abate.” In Estes, the court noted that the employer/carrier began providing benefits starting within just two days of the claimant’s accident in 2021 and continued doing so through January 2023. Consequently, the court held that the subsection (2) one year “tolling clock” promptly stopped the running of what the opinion refers to in different places as subsection (1)’s two year “limitations-period clock,” the “ultimate clock,” and the “master clock,” which is the “ultimate arbiter of time.” In other words, at the moment Estes received her first benefit, the two-year master clock stopped ticking and would only start again after one year from receipt of that benefit. However, since Estes continued to receive benefits, the master clock would never start until one year after she received last of these benefits—through at least January 2024. Therefore, when Estes filed her PFB in June 2024 (seeking a one-time physician change and benefits for the same injuries), she was only about six months into the running of the two-year master clock. The majority opinion rejected the various arguments raised by the two dissenting opinions that centered their objections on the practical workability of the new methodology, its economic impact, and stare decisis. The majority centered its approach on the “plain and ordinary meaning of the enacted text.” The plain and ordinary meaning of the Estes case itself is that the older “two years from the accident date/one year from the last benefit” methodology is gone. Unless the Supreme Court reversed Estes or the legislature amends the statute, parties must understand that provision of benefits at the outset of a claim will stop the clock, potentially for significant lengths of time.
