Nelson & Co. v. Holtzclaw

In Nelson & Co. v. Holtzclaw, 566 So. 2d 307, 309 (Fla. 1st DCA 1990), the Court noted that, because of the "periodic nature of wage loss, elements which might change from period to period . . . can be relitigated on successive claims." However, the Court also reaffirmed the general principle that "non-recurring issues" which were mature at the time of a prior merits hearing but not litigated may not be raised at a subsequent merits hearing because of the doctrine of res judicata. Id.