Case Review: Mohammed Bouayad v. Normandy Insurance Co

Mohammed Bouayad v. Normandy Insurance Co is currently under review by the Florida Supreme Court. The case has the potential to reshape how workplace injuries are defined and compensated in Florida. At the heart of the matter is a tragic shooting and a legal debate with potentially far-reaching consequences for employees and employers alike.
Case Background:
Mohammed Bouayad, a general manager at Value Car Rental located near Orlando International Airport, was shot seven times late at night while walking between his workplace’s kiosk and office. The assailant was never clearly identified, and the motive remains uncertain. Bouayad survived but sustained life-altering injuries.
The Judge of Compensation Claims (JCC) initially ruled in Bouayad’s favor, finding that his employment substantially contributed to the risk of injury. However, the First District Court of Appeal reversed that decision, arguing the shooting stemmed from a personal dispute involving Bouayad’s son and a man named Robert Aponte.
Legal Question: Personal Dispute or Work-Related Risk?
The central issue is whether Bouayad’s injuries “arose out of” his employment, which is a key requirement for workers’ compensation eligibility. Normandy Insurance contends the shooting was a targeted, personal attack unrelated to Bouayad’s job duties. Bouayad’s legal team argues the location, timing, and nature of his work exposed him to heightened risks, making the injury compensable under Florida law.
This debate reflects a broader legal principle emphasized in recent commentary: the burden remains on the claimant to establish a causal connection between the injury and the employment. As noted in a recent article by Marshall Dennehey, courts continue to require claimants demonstrate the employment contributed to the risk of injury, not only that the injury occurred at work. This standard is particularly challenging in cases involving violence or unknown assailants, where motive and context are often unclear.
Current Status
The Florida Supreme Court heard oral arguments on June 3, 2025, and the case remains pending. Multiple amicus briefs were filed in support of Bouayad, underscoring the case’s significance. Notably, the Florida State Lodge, Fraternal Order of Police (FOP) submitted a brief arguing that requiring injured workers to prove an assailant’s motive sets an unreasonable standard. They cautioned such a precedent could jeopardize benefits for law enforcement officers and others injured under similar circumstances.
Why This Case Matters
If the Supreme Court sides with the insurer, it could set a precedent allowing carriers to deny claims by framing violent incidents as stemming from personal disputes rather than occupational hazards. This would narrow the scope of compensable injuries and potentially leave workers unprotected in ambiguous or high-risk environments.
Conversely, a ruling in favor of Bouayad could affirm workplace conditions, such as late-night shifts, high-crime areas, and lack of security, can contribute to compensable risks, even when the assailant’s motive is unclear.
While this case is still under review, the case poses a test for how Florida interprets the “arising out of employment” standard.
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