Full Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________ No. 1D2025-0079 _____________________________ NANCY ESTES, CORRECTED PAGE: 50 CORRECTION UNDERLINED IN RED MAILED: March 30, 2026 Appellant, BY: KS v. PALM BEACH COUNTY SCHOOL DISTRICT, and DAVIES CLAIMS NORTH AMERICA, INC., Appellees. _____________________________ On appeal from the Office of the Judges of Compensation Claims. Gregory J. Johnsen, Judge of Compensation Claims. Date of Accident: September 30, 2021. March 23, 2026 EN BANC OSTERHAUS, C.J. In 1994, a comprehensive revision of the Workers’ Compensation Law became effective in Florida. As part of that overhaul, the Legislature replaced a statute of limitations regime in § 440.19(1), Florida Statutes, that had allowed claimants to obtain successive two-year extensions to seek benefits. The revised law took a stricter tolling approach under which a claimant’s receipt of injury-related treatment or benefits would “toll the [original two-year] limitations period set forth above . . . for 1 year from the date” that the benefits were provided or paid. § 440.19(2), Fla. Stat. (emphasis added). Nancy Estes’s case turns on the meaning of this tolling provision. Because the term “toll” here means to suspend, stop temporarily, or abate the “limitations period set forth above,” rather than extending a discrete one-year period to file additional claims, we set aside the final order which dismissed Estes’s petition for benefits on timeliness grounds. 1 I. Nancy Estes was a teacher employed by the Palm Beach County School District. On September 30, 2021, she tripped and fell on the job sustaining an accidental injury that was accepted as compensable by Appellees, the employer/carrier (E/C). The E/C paid workers’ compensation medical and indemnity benefits to Estes for about sixteen months, from October 2021 to January 2023. According to the parties’ hearing stipulation, the last date the E/C furnished any benefit was January 26, 2023. After that, the E/C filed a Notice of Denial on February 8, 2023, signaling its intention to deny any additional future medical treatments or benefits based on allegations that the accident was not the major contributing cause of her need for such treatments or benefits. In June 2024, about seventeen months after receiving her last benefits, Estes filed a petition for benefits (PFB). She sought a one- time change in orthopedists and other benefits. The E/C denied her claims contending that the statute of limitations barred them all. 1 This appeal has been decided en banc because, as discussed below, it corrects our interpretation of § 440.19(2) in a way that directly conflicts with how several previous panels of this court applied the tolling provision in cases such as: Orange Cnty. Sch. Bd. v. Best, 728 So. 2d 1186, 1188 (Fla. 1st DCA 1999); Claims Mgmt., Inc. v. Philip, 746 So. 2d 1180, 1181 (Fla. 1st DCA 1999); Medpartners/Diagnostic Clinic Med. Grp. v. Zenith Ins. Co., 23 So. 3d 202, 204, 206 (Fla. 1st DCA 2009); Varitimidis v. Walgreen Co./Sedgwick Claims Mgmt. Services, Inc., 58 So. 3d 406, 407–08 (Fla. 1st DCA 2011); Sanchez v. Am. Airlines, 169 So. 3d 1197, 1198 (Fla. 1st DCA 2015). See Fla. R. App. P. 9.331(a) (allowing for en banc hearings if “necessary to maintain uniformity in the court’s decisions”). 2 The Office of the Judges of Compensation Claims took up the matter and, by agreement of the parties, held a first-step final hearing, focusing upon the timeliness of Estes’s petition and the proper application of the limitations and tolling provisions in § 440.19. The PFB had been filed more than two years after the accident and more than a year after the furnishment of the last compensation benefit. And so, the Judge of Compensation Claims (JCC) followed the statute-of-limitations approach from Best, Philip, and similar precedents and concluded that § 440.19(1)’s two-year statute of limitations had lapsed after having never been suspended or abated by operation of § 440.19(2). Instead, the final order concluded that § 440.19(2) had gained Estes a discrete extension to file her claim calculated one year from the date on which she last received treatment or benefits from the E/C. The JCC’s Final Order thus dismissed with prejudice Estes’s entire PFB on statute of limitations grounds. The Final Order alternatively considered Estes to have raised compensability issues, to which the tolling provision in § 440.19(2) doesn’t apply. Estes subsequently appealed and argued that the tolling provision had been incorrectly interpreted and applied. In Estes’s view, § 440.19(2) suspended the original two-year statute of limitations clock for a substantial period, such that her PFB was filed well within the applicable statutory deadline and shouldn’t have been dismissed as untimely. More specifically, because the E/C had furnished Estes care and benefits for sixteen months, starting almost immediately after her injury until January 2023, those benefits tolled—meaning suspended or abated—the running of § 440.19(1)’s two-year limitations clock until one year after the E/C furnished her last treatment and benefits. And so, the two- year limitations clock didn’t even begin running again until the expiration of the separate one-year tolling clock established by § 440.19(2), which was January 2024 at the soonest. Consequently, due to the tolling, Estes claimed to have most of the original two- year limitations period still intact when she filed her PFB in June 2024. 3 II. A. This case requires us to decide whether the E/C’s provision of workers’ compensation treatment or benefits suspends the running of the two-year statute of limitations in § 440.19. Estes argues that her June 2024 petition for benefits was timely filed because her receipt of injury-related benefits through January 2023, suspended § 440.19(1)’s two-year limitations clock until one year after she received the last benefits and then resumed running in January 2024 (which gave her until January 2026 to file her PFB). Whereas the E/C views the two-year statutory limitations period to have never been stopped after the date of the accident, except that claimant got the benefit of a separately running one- year extension, which ran past the end of the limitations period, ending one year after receiving her last treatment or benefits in January 2023 (which gave her only until January 2024 to file a PFB). 2 The history of legislative revisions to § 440.19 is relevant to analyzing the parties’ competing statute-of-limitations arguments. Starting in 1994, the Legislature changed the text of the operative statute of limitations provision in § 440.19 from an extension- based regime to a tolling-based one. Before 1994, the pertinent text stated as follows: (a) The right to compensation for disability, rehabilitation, impairment, or wage loss under this chapter shall be barred unless a claim therefor which meets the requirements of paragraph (e) is filed within 2 years after the time of injury, except that, if payment of compensation has been made or remedial treatment or rehabilitative services have been furnished by the 2 Estes also argued on rehearing before the JCC that her limitations period extended even further because payments for her benefits were made by the E/C on a later date. We see, however, no error in the JCC’s rejection of that argument on preservation grounds. 4 employer on account of such injury, a claim may be filed within 2 years after the date of the last payment of compensation or after the date of the last remedial treatment or rehabilitative services furnished by the employer. This limitations period shall not be tolled or extended by the failure of the employer or carrier to file a notice of injury. . . (b) All right for remedial attention under this section shall be barred unless a claim therefor which meets the requirements of paragraph (e) is filed with the division within 2 years after the time of injury, except that, if payment of compensation has been made or remedial attention or rehabilitative services have been furnished by the employer without an award on account of such injury, a claim may be filed within 2 years after the date of the last payment of compensation or within 2 years after the date of the last remedial attention or rehabilitative services furnished by the employer; and all rights for remedial attention or rehabilitative services under this section pursuant to the terms of an award shall be barred unless a further claim therefor is filed with the division within 2 years after the entry of such award, except that, if payment of compensation has been made or remedial attention or rehabilitative services have been furnished by the employer under the terms of the award, a further claim may be filed within 2 years after the date of the last payment of compensation or within 2 years after the date of the last remedial attention or rehabilitative services furnished by the employer. However, no statute of limitations shall apply to the right for remedial attention relating to the insertion or attachment of a prosthetic device to any part of the body. . . § 440.19(1)(a)−(b), Fla. Stat. (1993) (emphases added). Under this pre-1994 regime, the Florida Supreme Court consistently treated the highlighted language as an extension of the statute of limitations as opposed to a suspension of it. See Sargent v. Evening Indep., Inc., 62 So. 2d 58, 60 (Fla. 1952); Watson v. Delta Airlines, Inc., 288 So. 2d 193, 196 (Fla. 1973) 5 (“Thus, on the dual basis of 1) ‘remedial’ attention having been voluntarily furnished within the two years required by the same exceptions within the two statutes, and 2) compensation voluntarily paid ‘without an award’ also within such two years, the claimant falls within the statutory exceptions in s 440.13(3)(b) and s 440.19(1)(a) and is within such ‘extended’ two year statute of limitations as a basis for recovery.” (emphasis added)); cf. Daniel v. Holmes Lumber Co., 490 So. 2d 1252, 1256 (Fla. 1986) (“Yet in the case of sections 440.13(3)(b) and 440.19(1)(a) no ambiguities exist. These statutes unequivocally state that so long as an employee files a claim within two years of the last voluntary compensation payment or dispensation of remedial treatment made without an award the claim is timely. Neither statute contains any reference whatsoever to the relevance of a two-year gap in time.”) (citations omitted); Holder v. Keller Kitchen Cabinets, 610 So. 2d 1264, 1267 (Fla. 1992) (“This provision has since been redesignated section 440.19(1)(a). This amendment removed the limitation restricting the exception to the two-year limitation period for filing a claim for compensation to situations where payment of compensation or remedial treatment was voluntarily provided. Thus, under the plain language of the amendment, the extension of the limitations period applies where payment of compensation or remedial treatment has been provided either voluntarily or pursuant to an order. Amendments, such as this, that lengthen the limitation period for filing a claim apply to claims that are viable at the time of the amendment.” (emphasis added) (citations omitted)). And so, with each new payment or treatment came a fresh two-year extension of the limitations period, leaving the original two-year period completely in its wake. This court also treated the prior language as either an extension of the limitations period or, similarly, a revival of the limitations period. See Iuen v. Live Wire Elec. Co., 538 So. 2d 1312, 1313 (Fla. 1st DCA 1989) (“Voluntary payment for remedial attention revives the two year limitation period, even if a two year period without compensation payments or remedial attention has already passed.”); Roe v. City Inv./Gen. Dev. Corp., 587 So. 2d 1323, 1324, 1325 (Fla. 1991) (“Hence the statute in its present form unambiguously states that a claimant is entitled to disability if a claim is filed within two years of the last remedial treatment. We therefore hold that a claim for disability is not time-barred, despite 6 a two-year gap between the injury and the claim, so long as the claim is filed within two years after the last remedial treatment.”); Bell v. Com. Carriers, 603 So. 2d 683, 685 (Fla. 1st DCA 1992) (“Under the clear language of the statute, the fact that the employer may not have intended to voluntarily provide remedial treatment and thus revive the statute of limitations for the 1981 injury is not controlling. Remedial treatment need not be voluntary in order to revive the statute. The critical question is whether the claimant has filed a claim within two years of the last compensation payment or remedial treatment causally related to a compensable injury.” (emphasis added) (citations omitted)). But in 1994 the Legislature tightened the statute of limitations provision in § 440.19, by pivoting to a tolling regime that fixed the two-year period in subsection (1) altogether as the ultimate basis for calculating the limitations period when benefits are provided. It stated: (1) Except to the extent provided elsewhere in this section, all employee petitions for benefits under this chapter shall be barred unless the employee, or the employee’s estate if the employee is deceased, has advised the employer of the injury or death pursuant to s. 440.185(1) and the petition is filed within 2 years after the date on which the employee knew or should have known that the injury or death arose out of work performed in the course and scope of employment. (2) Payment of any indemnity benefit or the furnishing of remedial treatment, care, or attendance pursuant to either a notice of injury or a petition for benefits shall toll the limitations period set forth above for 1 year from the date of such payment. This tolling period does not apply to the issues of compensability, date of maximum medical improvement, or permanent impairment. (3) The filing of a petition for benefits does not toll the limitations period set forth in this section unless the petition meets the specificity requirements set forth in s. 440.192. 7 § 440.19(1)−(3), Fla. Stat. (1994) (emphases added). Using the word “toll” to establish a “tolling period” departed from the previous statute’s “except[ion]” and extension of the limitations period. The revision reined in a previously more claimant-friendly regime that gave claimants rolling two-year extensions of the limitations period. Under the revised statute, the original term would remain the base two-year limitations period for seeking benefits but would allow for qualifying events to “toll” the two-year period for a year. The Legislature did not define “toll” in the revised statute. We must do so here because our past cases have not given it proper effect. “Toll” is a legal term with an established, ordinary meaning. See Debaun v. State, 213 So. 3d 747, 751 (Fla. 2017) (quoting Sch. Bd. of Palm Beach Cnty. v. Survivors Charter Sch., Inc., 3 So. 3d 1220, 1233 (Fla. 2009) (“Where, as here, the [L]egislature has not defined the words used in a [statute], the language should be given its plain and ordinary meaning.” (alterations in original)). Dictionaries can supply the “best evidence” of ordinary meaning. Conage v. United States, 346 So. 3d 594, 599 (Fla. 2022). Where “toll” is used in the context of a statutory limitations period, dictionaries define it as meaning “to suspend or stop temporarily as the statute of limitations is tolled during the defendant’s absence from the jurisdiction and during the plaintiff’s minority.” Black’s Law Dictionary 1488 (6th ed. 1990); see also Black’s Law Dictionary 1495 (7th ed. 1999) (defining “toll, vb. . . . 2. (Of a time period, esp. a statutory one) to stop the running of; to abate <toll the limitations period>”); Hankey v. Yarian, 755 So. 2d 93, 95 n.3 (Fla. 2000) (citing the Black’s Law Dictionary definition of “toll” in a statute of limitations case); Sheffield v. Davis, 562 So. 2d 384, 386 (Fla. 2d DCA 1990) (describing the “plain and obvious” meaning of “toll” in accordance with various contemporaneous dictionary definitions and cases); cf. Artis v. D.C., 583 U.S. 71, 80– 81 (2018) (defining “tolling” to effect a suspension of the limitation period’s running, a suspension that can be lifted, prompting the period to “start[] running again when the tolling period ends, picking up where it left off”). 8 That “toll” means “suspend,” “stop temporarily,” or “abate” in subsection (2) can also be deduced from §440.19’s description of tolling under subsection (5). There, if a person is a minor, the limitations period is tolled while that person has no guardian or other authorized representative, but the period shall begin to run . . . in the case of a minor, if no guardian is appointed before the minor becomes of age, from the date the minor becomes of age. §440.19(5), Fla. Stat. (2021) (emphases added). This subsection works by having the tolling “suspend” the two-year limitations period from subsection (1) and remain stopped (for years potentially) before it “begin[s] to run” again after the stated condition occurs—the minor becomes of age. Conversely, subsection (5) does not toll by adding time as the E/C argues. For example, the limitations period in subsection (5) wouldn’t be calculated in the case of a guardian-less, fifteen-year-old claimant by simply granting a three-year extension until the coming-of-age date and then ending the limitations clock on the eighteenth birthday. See § 743.07, Fla. Stat. (removing the disability of nonage at age eighteen). Rather, subsection (1)’s two-year-limitations- period clock is “tolled,” or suspended, by subsection (5) until the guardian-less minor comes of age, at which time the claimant gets two years to file a claim (until age 20). See Benton v. ICR Electric, 852 So. 2d 295, 296 (Fla. 1st DCA 2003) (holding that “[e]ven if the petition for benefits was filed more than two years after the death of the claimant, a minor’s claim would not be barred by the statute of limitations . . . [because] the limitations period . . . will not begin to run until a guardian or representative is appointed or until they reach the age of majority”). In view of how tolling works in subsection (5), we cannot interpret it to mean something different in subsection (2). Use of the dictionary definition of “toll” finds additional support in contemporaneous, 1990’s-era Florida Supreme Court interpretations of other statutes of limitations provisions. Just one year before the revision to §440.19(2) took effect, the Florida Supreme Court discussed how “extension” and “tolling” create different effects on the running of limitations periods. In Tanner v. Hartog, 618 So. 2d 177 (Fla. 1993), for example, the court 9 explained, albeit in dicta, that section 766.106(4), Florida Statutes, which deals with medical malpractice actions, tolls the statute of limitations for at least 90 days when a prospective claimant notifies each prospective defendant of an intent to initiate litigation. Id. at 182-83. Following the 90-day period, the new statute of limitations deadline would be calculated based on “the time that was remaining in the limitations period” when the 90- day period began (unless less than 60 days remained, in which case the deadline would be in 60 days). Id. at 183-84. The court’s recognition of “the time that was remaining” shows that “toll” in 1994 meant to “suspend” the running of the limitations clock until the tolling period ends. Six years after the 1994 revisions to §440.19, the Florida Supreme Court reiterated that the “PLAIN MEANING” of the word “toll” in a statute-of-limitations context was “routinely and consistently interpreted as suspending the running of the statute of limitations time clock until the identified condition is settled.” Hankey, 755 So. 2d at 96–97 (citing district court cases from 1991 and 1995). The Court then applied this plain meaning of “toll” to the same medical malpractice statute discussed in Tanner: “Because the word ‘toll’ has been consistently used by the Legislature and interpreted by the courts to mean ‘suspend’ when used in a statutory limitations context, we conclude that it was intended to have the same meaning in section 766.106(4).” Id. at 97. The discussion in Hankey also makes clear that, in Florida, an “extension” of a limitations period and a “tolling” of a limitation period are different concepts, such that there is significance to the Legislature’s choice between these terms in the limitations context. The Court explained as follows: Section 766.106(4) of the statutory scheme also provides that if there are less than sixty days remaining to file suit before the end date of the original two-year limitations period at the time the claimant filed the notice of intent to initiate litigation, then the claimant shall have sixty days from the time when the notice of termination of negotiations is received by him to file suit. If, however, there were more than sixty days remaining to file suit before the end date of the original two-year limitations period when the claimant filed the notice, then the 10 claimant only has the time remaining in the original two- year period to file suit. This provision provides additional time to the limitations period separate and apart from the ninety days of tolling, but only in the limited circumstances set out in the statute where less than sixty days remain to file suit at the time the claimant files the notice of intent. Id. (emphasis added); see also id. at 98 (agreeing that “the ‘extension’ provided for under section 766.104(2) is a genuine extension of time to be added to the limitations period, rather than a tolling (suspension) as provided for under section 766.106(4). . . . Hence, this time period is to be tacked on to the end of the limitations period and does not run simultaneously with the separate ninety-day tolling period provided in section 766.106(4).”) (emphases added). We likewise conclude here that the same term “toll,” added to § 440.19(2) in 1994, carries the exact meaning discussed in Tanner and Hankey. In other words, tolling operates by “interrupt[ing] the running of the statutory limitations period, the statutory time is not counted against the claimant during that . . . period. In essence, the clock stops until the tolling period expires and then begins to run again.” Hankey, 755 So. 2d at 97. The continuing interaction of the two time-periods set forth in § 440.19(2)— “shall toll the limitations period set forth above for 1 year”—reveals the Legislature’s intention to fix the limitations period set forth in subsection (1) as the base period with suspensions of its clock triggered by qualifying tolling events. This court’s previous decisions, on the other hand, erred by not interpreting and applying the tolling provision in §440.19(2) according to this plain meaning. In Orange County School Board v. Best, 728 So. 2d 1186, 1188 (Fla. 1st DCA 1999), for instance, we faced the issue of whether the one-year tolling period superseded the two-year limitation period. We proceeded to conflate the definitions of “toll” and “extend” in pronouncing that the two-year, original statute of limitations period could not be stopped. We decided that the limitations period could only be extended under subsection (2) for a discrete one-year period running from the date that benefits were provided: “A petition is timely if filed within two 11 years of the date of accident or, even thereafter, if filed within one year of the last date the petitioner received medical treatment or indemnity benefits.” Id. (emphasis added); see also id. at 1187 (“We read section 440.19(1), Florida Statutes (1995), as the statute of limitations generally applicable in workers’ compensation cases, subject to the exceptions—which extend the limitations period in certain circumstances—set out in the other subsections of section 440.19. . . . Subsections that follow subsection (2) can have no effect other than to extend the two-year statute of limitations set out in section 440.19(1), Florida Statutes (1995).” (emphasis added)). By conflating the concepts of tolling and extending time, we concluded that “Section 440.19(2) has no practical effect until after the two- year period provided for in section 440.19(1) expires. As long as the petition is timely under either section 440.19(1) or section 440.19(2), the statute of limitations is no bar.” Id. (emphases added). Our court has repeated this interpretative error ever since. In Philip, for example, we settled for a reference to legislative intent and simply concluded that our construction was a “more reasonable one.” 746 So. 2d at 1182 (reading the new term “toll” as having “the effect of extending the limitations period”); Medpartners/Diagnostic Clinic Med. Grp., 23 So. 3d at 204 (referring to the term “toll” as meaning “toll or extend” (emphasis supplied)); Varitimidis, 58 So. 3d at 407–08; Sanchez, 169 So. 3d at 1198 (treating “toll” as meaning “extend”). Our duty, however, is to faithfully apply the plain and ordinary meaning of the enacted text. We discharge that duty now by interpreting the term “toll” in § 440.19(2) in accordance with its accepted meaning to suspend or stop temporarily the limitations period provided in subsection (1). This outcome honors the express relationship established between the limitations period and tolling period prescribed by subsection (2). It also brings this law into conformity with the other limitations provisions in Florida law that establish time-certain tolling periods, such as § 766.106(4), discussed above (setting a ninety-day tolling period for some medical malpractice claims), and § 624.155(3)(e) (setting a sixty- day period for some insurance claims). Under each of these provisions, like with § 440.19, parties must manage two important statutory clocks that run separately: the limitations-period clock and the tolling clock. Cf. Stimpson v. Ford Motor Co., 988 So. 2d 1119, 1121 (Fla. 5th DCA 2008) (quoting 135 Fla. Jur. 2d 12 Limitations and Laches § 87 (2008) (describing tolling of a limitations period to be “analogous to a clock stopping and then restarting”). And so, here, under § 440.19, after an employee knows or should have known of a qualifying workplace injury, the two-year limitations-period clock begins to run. But then, if an E/C provides benefits after the injury, the limitations-period clock is stopped while the one-year tolling clock begins running (and then restarts after every subsequent provision of a benefit). The limitations-period clock restarts again one year after the provision of the last benefit. In this way, tolling in § 440.19 accords with how tolling statutes normally work; it “suspend[s] the running of the statute of limitations time clock until the identified condition is settled.” Hankey, 755 So. 2d at 96. Applying the law to the situation here, the parties agreed that Estes received many workers’ compensation benefits for injuries starting within two days of her workplace accident in 2021 for a period extending through January 2023. As a result, the one-year tolling clock promptly stopped the running of the two-year limitations-period clock after the accident until one year after Estes received last of these benefits—through at least January 2024. And so, 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 limitations-period clock. In other words, the date of her PFB fell squarely within the running of the two-year limitations-period clock, which wouldn’t have expired until January 2026 under these facts. For this reason, we set aside the final order’s dismissal of the petition. In reaching this result, we respectfully acknowledge the arguments of our dissenting colleagues on the issue of what tolling means. They assert that we shouldn’t depart from the previous cases and that the use of “tolling” in the 1994 revision to subsection (2) didn’t alter the mechanics of the old extension-based regime. They point out that our court at times even characterized the pre- 1994 extension regime as “tolling” the limitations period. And then, citing “the well-established rule of statutory construction that the Legislature is presumed to be cognizant of relevant judicial decisions when enacting statutes,” they assert that statutory construction canons require us to continue elevating our 13 incorrect interpretation of §440.19(2) over its plain and ordinary meaning. Potter v. Potter, 317 So. 3d 255, 258 (Fla. 1st DCA 2021). But the prior-construction canon would not apply here. Although some of our cases referred to “tolling” under the pre-1994 limitations period regime, none of them interpreted the term itself, or supplied a definition of “toll” for the Legislature to latch onto. So that from our sporadic use of “tolling” in the old cases, we can hardly ascribe an intention by the Legislature to abandon its plain meaning and adopt an unconventional definition that our court never adopted prior to the statutory revision. See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 322 (2012) (explaining that the prior-construction canon applies when the word or phrase has received “authoritative construction” by the highest court or “uniform construction” by inferior courts). The dissenters’ definition of tolling also fails to account for the Legislature’s pivot in the 1994 revision to language that crafted limitations-period primacy in the basic two-year statute of limitations in subsection (1). The Legislature didn’t just use the new word “toll” in § 440.19(2) and leave the statute otherwise intact. Rather, it abandoned a regime that previously discarded the base two-year statute of limitations in long-term-injury/benefit situations in favor of extending a wholly discrete series of rolling two-year limitations periods. The revised statute went in another direction. It called for establishing a durable two-year limitations period to serve as the ultimate clock and basis in every case, subject to intermittent stoppages: “Payment . . . or the furnishing of [any benefit] . . . shall toll the limitations period set forth above for 1 year from the date of such payment.” § 440.19(2), Fla. Stat. (emphasis added). Under this revised § 440.19(2) regime, tolling is always accomplished in reference to the subsection (1) limitations period, which controls as the ultimate arbiter of time. Once the “limitations period set forth above” has run, there is nothing left to toll and tolling becomes unavailable. Conversely, the dissenters’ view of tolling promptly displaces “the limitations period set forth above” two years after the workplace injury and resurrects the legislatively replaced successive-extension model by giving a series of rolling one-year extensions to claimants in long-term- injury/benefit situations without regard to the limitations period 14 in subsection (1). Because the dissenters’ view abandons the Legislature’s express intention in subsection (2) to have tolling anchored by reference to the subsection (1) limitations period, we must reject it. We also aren’t convinced that the dissenters’ economic argument proves that its interpretation is the correct one. While we acknowledge that the Legislature’s 1994 revision stemmed from fiscal troubles with Florida’s workers’ compensation system, both the majority’s and dissenters’ interpretations here appear to improve the economics of the prior system (though no record evidence specifically addresses the economics of either approach). The dissenters’ hypothesis and chart notwithstanding, it isn’t for us to decide statutory interpretation questions based upon the economics of things if the plain text of the law fails to support that result. And so here, we must heed the Legislature’s decision to craft a tolling provision that establishes the subsection (1) limitations period as the master clock over the possibility that the dissenters’ interpretation may be a less costly regime. Finally on the tolling issue, we understand the dissenters’ stare decisis-based preference for us to stick with our previous wrongly decided § 440.19(2) cases. But here “we have chosen to reassess a precedent and have come to the conclusion that it is clearly erroneous.” State v. Poole 297 So. 3d 487, 506-07 (Fla. 2020). Now, “[t]he proper question becomes whether there is a valid reason why not to recede from that precedent.” Id. (emphasis in original). The critical consideration here is reliance. Id. Poole instructs that reliance interests are at their lowest in cases “involving procedural . . . rules,” which is exactly what is at stake with § 440.19’s statute of limitations regime. With low-stakes reliance interests in view, we must elevate the goals of correctly interpreting § 440.19’s limitations-period regime, which vindicates the Legislature’s preferred parameters for this regime. We therefore hold en banc that the tolling provision in § 440.19(2) suspends or stops temporarily the limitations-period clock established in subsection (1), instead of extending separate one- year limitations periods for claimants to file claims in these cases. B. 15 In reaching this conclusion, we likewise reject the E/C’s alternative argument that characterizes this whole case as one big compensability issue to which § 440.19(2)’s tolling provision doesn’t apply. While it is true that tolling under § 440.19(2) doesn’t apply to the issue of compensability, here, the compensability of Estes’s original trip-and-fall injuries was settled long ago and isn’t at issue. There has been no evidence presented—to this point at least—that this case involves any different injury or accident to which a separate compensability determination might apply. And Estes needn’t re-establish the compensability of the same injuries. See Meehan v. Orange County Data & Appraisals, 272 So. 3d 458, 461 (Fla. 1st DCA 2019) (discussing how “once a claimant has established compensability of an injury . . . the E/C cannot challenge the causal connection between the work accident and the injury [but] may only question the causal connection between the injury and the requested benefit”). We must be careful here not to “[blur] the distinction between compensability and entitlement to benefits.” Checkers Rest. v. Wiethoff, 925 So. 2d 348, 349–50 (Fla. 1st DCA 2006); Pinellas Cnty. Transit Auth. v. Jackson, 424 So. 3d 984, 986 (Fla. 1st DCA 2025 (specifying that “[c]ompensability involves the work-place-related existence and cause of an injury and not benefits-entitlement issues”). Under the facts here, the E/C accepted compensability of Estes’s workplace injuries immediately after the accident and then paid for treatment and benefits for sixteen months. See § 440.34(3)(c), Fla. Stat. (1994) (referring to the “issue of compensability” where “a carrier or employer denies that an accident occurred for which compensation benefits are payable”). In turn, the E/C conceded Estes’s injury to be “accepted as compensable” in the pretrial stipulation in this case: it marked “X” in “Yes” box and left the “No” box empty. It also agreed that the following injuries or conditions are accepted as related to the accident: “E/C/SA: Exacerbation of the Right Knee” (while the E/C also noted, fairly enough, that it “has not accepted compensability for those conditions deemed to be unrelated, pre-existing or degenerative in nature and/or barred by the Statute of Limitations”). On the average weekly wage issue the parties’ pretrial stipulation differed only as to the amount involved: Estes claimed a base wage of $1527.30, and the E/C claimed $1112.56. And so, the parties agreed that Estes’s PFB involved already- 16 compensable injuries, even if the parties differed about her right to (and the amount of) specific benefits associated with these injuries. Of course, the JCC put to the side all the substantive issues in this case, so we know very little about Estes’s claims. The only issue teed up by the parties’ stipulation was the E/C’s statute of limitations defense and how § 440.19(2)’s tolling provision applied (both parties agreed that it applied). According to the E/C’s stipulation: The [E/C] established a prima facie case that the PFB is barred by the Statute of Limitations as the date of the accident was over two years ago on 9/30/2021; the last medical provision provided to the Claimant was on 1/26/2023. Therefore the SOL expired on 1/26/2024. The Claimant’s PFB was not filed until 6/13/2024. With this stipulation the E/C conceded that the tolling provision applied here to extend the statute of limitations to 1/26/2024, but no further. And so, both sides agreed that the tolling provision applied here, just for different periods based on their different interpretations of “toll.” This is different from the dissenters’ view of compensability that the tolling provision never applied here. We acknowledge the dissenters’ repeated assertions that Estes made pivotal stipulations about compensability that totally control this case. But the record doesn’t show it. We can find no such stipulation from Estes. Consider the PFB. Estes listed eight claims stemming from her compensable accident and injuries. She sought various indemnity benefits, a one-time-change of her orthopedic physician “to evaluate and treat claimant’s work- related injuries,” attorneys’ fees and costs, and “authorization and determination of financial responsibility” of claimant’s knees and right wrist (original injuries). Even if these benefit claims might require a major contributing cause analysis to determine Estes’s entitlement to additional benefits, they do not resurrect the long- settled compensability issue. We also understand that Estes’s PFB stated a ninth, single claim for “compensability” apparently covering the already- 17 accepted knees and wrist. But the scope of this claim hasn’t been fleshed out in the record because the JCC didn’t take evidence or address any substantive claims. This claim was asserted against a backdrop of the E/C accepting and providing extensive benefits for 17 months before filing a notice of denial of compensability and unilaterally declaring that Estes