Giraldo v. Agency for Health Care Administration
Resolving an express conflict between the First and Second DCAs, the Florida Supreme Court held that under the federal Medicaid Act, AHCA may lien only the past medical expenses portion of a Medicaid recipient's third-party tort recovery, not the portion allocable to future medical expenses. The Court quashed the First District's contrary decision, approved Willoughby, and directed that the lien be reduced to the $13,881.79 shown by uncontradicted expert testimony as the past-medicals allocation of the $1 million settlement.
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Key facts
- Medicaid recipient Giraldo received a $1 million third-party tort settlement; AHCA asserted a lien against the entire settlement amount under its Medicaid lien statute.
- The trial court and First District Court of Appeal upheld AHCA's lien on the full settlement amount, while the Second District had previously limited liens to past medical expenses only, creating a conflict among district courts.
- +2 more key facts with a free trial
Why it matters
This is the controlling Florida authority capping Medicaid liens at the past-medicals portion of any tort recovery — essential for every personal injury lawyer negotiating settlements and allocations where AHCA asserts… — full analysis with a trial
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