Crandall Medical Consulting, LLC v. Gainey
A Medicaid waiver support coordination company and its employee, assigned by the Agency for Persons with Disabilities to a developmentally disabled adult, moved for summary judgment on sovereign immunity under section 768.28(9)(a). The First DCA reversed the denial, holding their undisputed deposition evidence of APD's right to control established agency status as a matter of law, and that a contract clause labeling them 'independent service providers' was not dispositive. The court also noted in a footnote that an LLC is not a 'corporation' for purposes of section 768.28(2)'s limited waiver, so the individual-agent immunity of section 768.28(9) applied to the LLC.
Key facts
- Crandall Medical Consulting, LLC and its employee provided support coordination services to a developmentally disabled adult under a Medicaid waiver program administered by the Agency for Persons with Disabilities.
- The trial court denied defendants' motion for summary judgment on sovereign immunity grounds, finding disputed issues of material fact regarding whether defendants were state agents despite a contract clause designating them as independent service providers.
- +2 more key facts with a free trial
Why it matters
This decision gives state contractors and Medicaid waiver providers a concrete roadmap to win early sovereign immunity dismissal under section 768.28(9)(a): submit deposition evidence of the agency's right to control… — full analysis with a trial
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