In Arand Construction Co. v. Dyer, 592 So. 2d 276 (Fla. 1st DCA 1991), the Court explained why lay testimony alone was not enough to establish causation, even under the less stringent and more straightforward "some causative connection" standard then in force: In the case at hand, the JCC based her finding of a causal connection on the testimony of the claimant: "I find that the testimony of the employee/claimant constitutes competent substantial evidence to establish the required causal connection between the accident and the resultant injury because the symptoms which he is experiencing are within the actual knowledge of the employee/claimant". Applied in this manner, the rule [requiring medical evidence] is rendered meaningless. The claimant's awareness of his own symptoms says nothing about the causes of those symptoms. In this case, the claimant knew that his back hurt; he could not, and did not, testify that his pain was caused either by the lifting incident or by an ongoing degenerative arthritic condition. Id. at 281.