Shands Jacksonville Medical Center, Inc., and University of Florida Board of Trustees, 1D2020-3605

The case involved a claim for compensation filed by the parents (the Chavezes) under Florida's Birth-Related Neurological Injury Compensation Plan (NICA), seeking benefits for their child’s birth injury.
After initial filings, the Chavezes amended their petition to expressly disclaim any entitlement to compensation under the Plan, opposing their original request.
Shands Jacksonville Medical Center and the University of Florida Board of Trustees (providers involved in the birth) intervened, seeking a determination that the child’s injury qualified as a NICA-compensable injury despite the Chavezes’ disclaimer.
The ALJ found the injury non-compensable; the intervenors (providers) appealed even as the Chavezes and NICA both agreed no compensation was due.
The appellate court sua sponte questioned its jurisdiction to review the ALJ’s order, given the absence of a live claim or controversy.
The case centers on the separation of powers, specifically whether quasi-judicial powers exercised by executive officers (ALJs) can have binding effect in private disputes or only within agency proceedings over public rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ had authority to adjudicate compensability after the claim was disclaimed	Intervenors argued the ALJ could decide compensability regardless of claimant’s position	Chavezes/NICA argued no claim existed, so no authority	ALJ had no authority; no live claim existed
Whether ALJ’s order could have preclusive effect in future malpractice suits	Providers argued ALJ’s finding would bar future claims in civil court	Chavezes/NICA argued such findings are non-binding	ALJ’s order was non-binding, advisory only
Whether an administrative order in absence of a live claim is reviewable on appeal	Providers claimed right to appeal adverse ALJ order	Chavezes/NICA claimed no justiciable controversy existed	Court lacked jurisdiction; no review possible
Whether Plan statutes or 1998 amendments gave exclusive ALJ authority over injury determinations	Providers said statute gives ALJ exclusive jurisdiction	Chavezes/NICA said amendments didn’t override earlier cases limiting ALJ power	Amendments did not abrogate precedent; no authority

Florida Birth-Related Neurological Injury Compensation Ass’n v. McKaughan, 668 So. 2d 974 (Fla. 1996) (an ALJ has authority to determine compensability only when a claim is filed by someone affirmatively seeking compensation)
Mandico v. Taos Construction, Inc., 605 So. 2d 850 (Fla. 1992) (circuit courts can determine their own jurisdiction even where statutory exclusivity defenses are raised)
State ex rel. B. F. Goodrich Co. v. Trammell, 192 So. 175 (Fla. 1939) (circuit courts are courts of broad, general jurisdiction that cannot be curtailed except clearly by statute or constitution)
Canney v. Bd. of Pub. Instruction of Alachua Cnty., 278 So. 2d 260 (Fla. 1973) (legislature cannot vest judicial power in administrative tribunals)
Broward County v. La Rosa, 505 So. 2d 422 (Fla. 1987) (administrative agencies may exercise quasi-judicial but not full judicial powers)