JCC Finds Door-to-Door Sales Crash Compensable Under Travel-Status Rule

In James Anthony Ettore v. Charter Communications, LLC/ESIS WC Claims, OJCC Case No. 26-001399NPP, Judge Neal P. Pitts addressed a bifurcated merits hearing limited to whether an April 3, 2025 motor-vehicle accident was compensable for a residential connectivity specialist who made door-to-door Spectrum sales calls across Central Florida.

The JCC credited the claimant and a neutral senior sales representative that the crash occurred while the claimant was driving from prior sales activity toward a nearby gated community to continue making sales calls. TripLog data still tracked the claimant at the accident location, and the order rejected the employer/carrier theory that he had already ended work or had deviated to go to Crunch Fitness before the crash.

Applying section 440.092(4) and recent First DCA travel-status cases, the JCC found the claimant was required to travel for work, was being compensated as a salaried employee, and was actively engaged in employment duties when the accident occurred. The accident was held compensable, with a later merits hearing reserved for specific medical and indemnity benefits.

Source: Compensation Order