Eastern Airlines, Inc., and GAB v. Crittenden and Travelers Insurance Co.

An employer and an insurance carrier appealed the decision of a Judge of Compensation Claims, awarding benefits to a flight attendant who suffered a bronchial condition caused by multiple exposures to cigarette smoke during her work as a flight attendant.  She had successive periods of disability during which she did not work and her condition would improve, whereupon she would return to work and her condition would worsen as a result of new exposure.  Travelers was the carrier at risk until February 1, 1987, when GAB assumed the risk.  After she returned to work on February 19, 1987, she sustained additional injurious exposures.  She was awarded benefits for her disabilities both before and after February 19, 1987.  The judge ruled that GAB would be solely responsible for all of the benefits.  The District Court of Appeal reversed, ruling that Travelers should be responsible for the benefits which were awarded for the prior period of time and GAB responsible for the later period.

596 So.2d 112 (Fla. App.1 Dist. 1992).