Florida Appeals Court Reverses Workers’ Compensation Award for Former MLB Player

The First District Court of Appeal of Florida has reversed a workers’ compensation award in favor of Austin Sodders, a former minor league pitcher for the Detroit Tigers, in a case challenging the calculation of his average weekly wage (AWW) following a shoulder injury.

The case, titled Detroit Tigers, Inc. and Sedgwick Claims Management Services, Inc. v. Austin Sodders, revolves around the proper method to determine Sodders’ AWW under Florida law. Sodders, who was injured on May 25, 2018, while playing for the Lakeland Flying Tigers, argued for a higher AWW based on a 12-month salary, while the appellants contended that it should reflect only his five-month playing season salary.

The lower court had previously calculated Sodders’ AWW by dividing his monthly salary of $1,500 by 4.3 weeks per month, resulting in an AWW of $348.84. However, the First District Court of Appeal found this method inconsistent with the terms of Sodders’ employment contract, which stipulated payment only during the five-month championship season.

Judge Long wrote in the decision that the JCC (Judge of Compensation Claims) abused his discretion by attributing a year-round salary to Sodders despite the contract’s explicit terms. The court emphasized that the AWW should be determined based on the contract or actual earnings, which in Sodders’ case was limited to the championship season.

The court’s reversal mandates that the JCC recalculates Sodders’ AWW in a manner consistent with the contract, potentially reducing his compensation significantly. The decision underscores the importance of adhering strictly to contract terms when determining workers’ compensation benefits.

Judge Bilbrey concurred, noting that while the contract method was appropriate in this instance, other cases might warrant consideration of actual earnings to ensure fair compensation. The ruling sets a precedent for future cases involving seasonal or contract-based employment in Florida.

This case highlights the legal complexities in workers’ compensation claims, particularly for athletes and other seasonal workers whose earnings do not follow a traditional pattern. The decision serves as a reminder for both employers and employees to understand the implications of employment contracts on potential compensation claims.