Noel v. North Broward Hospital District, 664 So. 2d 989 (Fla. 4th DCA 1995).

In this medical malpractice action brought by a child's parents against physicians who were hired as part-time "consultants" at a health care facility operated by HRS, the appellate court found that one of the defendant professional associations (P.A.) was not liable for an individual physician's alleged malpractice because the physician was not acting in the scope of his employment for the P.A. when the malpractice was allegedly committed. The appellate court also reversed a summary judgment in favor of another P.A. because a genuine issue of material fact existed as to whether sovereign immunity could extend to them.