A Florida appeals court has overturned a default judgment against Affinity Health Partners, LLC, in a case involving unpaid medical staffing fees. The court ruled that the trial court awarded unliquidated damages without providing Affinity proper notice or an opportunity to present evidence. This decision affects how damages are assessed in default judgments, particularly in business contracts.
The case, Affinity Health Partners, LLC v. Hayes Locums, LLC, was filed in the District Court of Appeal of Florida, under docket number 4D2025-2096, and the ruling was issued on August 19, 2026. The ruling emphasizes the importance of procedural fairness in legal proceedings, especially when significant financial amounts are at stake.
Background
Affinity Health Partners, a health care management firm, entered into a contract with Hayes Locums, a medical staffing company, to provide medical professionals for its facilities. The agreement, known as the Service Agreement, did not specify the payment amounts but stated that these would be detailed in separate confirmations for each assignment. Hayes was responsible for billing Affinity bi-weekly based on the agreed-upon fees.
In its amended complaint, Hayes alleged that Affinity failed to pay over $200,000 for services rendered. However, the complaint lacked specific details regarding the payment amounts, only including a summary of invoices that did not clarify the rates or hours worked. Despite this, Hayes sought a default judgment after Affinity did not respond to the complaint or attend a scheduled hearing.
The Ruling
The District Court of Appeal ruled in favor of Affinity, reversing the trial court's final default judgment. The court found that the trial court had improperly awarded unliquidated damages without a properly noticed trial. The ruling stated, "The trial court erred by awarding unliquidated damages in the final default judgment without a properly noticed damages trial." The judges involved in the ruling included Judge Forst, Chief Judge Gerber, and Judge Shaw.
The court emphasized that a defaulting party is entitled to notice and an opportunity to be heard on unliquidated damages. It highlighted that the trial court's hearing did not provide an evidentiary basis for determining the damages, as it was based solely on the allegations in the complaint. The court noted that the Service Agreement and the Invoice Sheet did not provide sufficient information to determine the exact amounts owed by Affinity.
Impact
This ruling has significant implications for businesses involved in contract disputes. It reinforces the necessity for clear documentation and proper procedures when seeking damages in court. The court's decision clarifies that unliquidated damages require a formal hearing where evidence can be presented and evaluated. This ruling may affect how similar cases are handled in the future, ensuring that parties have the opportunity to defend themselves adequately.
Moreover, the ruling may lead to more stringent requirements for plaintiffs to provide detailed documentation when seeking damages in default judgments. It serves as a reminder that procedural fairness is crucial in legal proceedings, especially when substantial amounts of money are involved.
What's Next
The case will be sent back to the trial court for a properly noticed damages trial to determine the unliquidated damages. Affinity may also have the option to appeal further, depending on the outcomes of the new trial and any subsequent motions.