Angela Samples v. Florida Birth-Related Neurological Injury Compensation Association

Summary

The court held that the parental-award provision provides one aggregate award of no more than $100,000 to the parents or legal guardians of an eligible child. Applying rational-basis review, the court concluded that the limitation is rationally related to preserving the Plan's actuarial soundness, and it rejected the vagueness and access-to-courts challenges because the provision supplies sufficient legal structure and a reasonable alternative remedy. The court answered the certified equal-protection question in the negative and approved the result below. Perry, J., concurring in part and dissenting in part, would have found an equal-protection violation and would not have reached the vagueness or access-to-courts issues.