The court finds that the judge erred by not ruling based on the notice that should have been provided within 52 weeks of the qualifying event versus when the symptoms manifested.

In the case of Andrew Wilkes v. Palm Beach County Fire Rescue and Preferred Government Claims Solutions; OJCC # 19-019645, West Palm Beach District, Judge Stephenson; Decision Date: Apr. 23, 2020, the judge held that a first responder’s PTSD (due to a drowning event) was compensable when analyzed from the date of manifestation. On appeal, the First District Court of Appeal held that the judge erred by not ruling based on the notice that should have been provided within 52 weeks of the qualifying event versus when the claimant’s symptoms manifested. Therefore, the case was reversed and denied due to untimely notice.

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