PLN Publisher Wins Settlement Records from Centurion in Florida Prisoner’s Wrongful Death
On June 24, 2025, Florida’s Seventh Judicial Circuit Court for Putnam County ruled that Centurion of Florida, LLC was acting as the functional equivalent of a state agency when it contracted with the state Department of Corrections (DOC) to provide healthcare to prisoners; therefore, it was obligated under the state’s public records law to provide a copy of a settlement agreement reached with a dead prisoner’s estate to the Human Rights Defense Center (HRDC), the nonprofit publisher of PLN and Criminal Legal News.
HRDC filed its request in June 2022, two months after Centurion settled with the Estate of Curtis Dettmann. The 31-year-old prisoner died in January 2018, days after arriving at DOC’s Reception and Medical Center (RMC) in Lake Butler. Centurion staffers providing medical care at the prison allegedly ignored his infective colitis as he quickly vomited away nearly 30 pounds and died, according to the complaint later filed on his behalf under 42 U.S.C. § 1983. See: McCrimmon v. Centurion of Fla., USDC (M.D. Fla.), Case No. 3:20-cv-00036.
Centurion refused HRDC’s request, arguing that it was a private entity not subject to the requirements of Florida’s Public Records Act (PRA), ch.119 § 01, et seq., Fla. Stats. Centurion then sued HRDC seeking a judgement preventing HRDC from filing public records requests with the company. HRDC then filed a countersuit in the case, which then held a one-day bench trial to decide the matter
As the court noted, this particular Centurion entity was created solely to contract with DOC to provide prisoner healthcare, and it had “no other function.” The DOC contract expressly stated that the agency was responsible for this function and delegating it to Centurion, which agreed in turn to indemnify DOC as a “contractor acting as an agent of the state” for any claims, including those filed under § 1983. Therefore, the court concluded, “Centurion meets the test for being a functional equivalent of a state agency”; not only did the firm “perform[] the traditional governmental function of providing healthcare to inmates” but also it “[did] so on behalf of [DOC] pursuant to the Contract.”
The settlement agreement was also a public record as defined under PRA, the court continued. Centurion did not dispute that DOC would be obligated to disclose it had the agency reached the settlement agreement on its own accord. Centurion’s own witness, Victoria Love, testified that DOC “was not a party to any settlement negotiations at mediation in the Federal Action,” the court recalled. Florida precedent also made the agreement a public record which Centurion was obligated to disclose, per Prison Health Servs., 718 So. 2d 205. Though sympathetic to Centurion’s motive in fighting disclosure—“to keep the future would-be plaintiff from knowing what [it] will settle for”—the court refused to ignore the “higher regard that Florida holds it’s (sic) public records laws.”
Accordingly, Centurion was ordered to produce a copy of the document within 14 days. HRDC, as prevailing party, was also directed to file a motion for legal costs and attorney’s fees. PLN will continue to update those details, as well as details of the settlement in Dettmann’s case. HRDC was represented by attorney James Slater of Slater Legal PLLC in Atlanta and Tallahassee, as well as HRDC Litigation Director Jonathan Picard. Joining him on brief were attorneys Jack Browning, Bruce Johnson, Caesar Kalinowski, and Shontee Pant of Davis Wright Tremaine LLP in Seattle. See: Human Rights Def. Ctr. v. Centurion of Fla. LLC, Fla. 7th Jud. Cir. (Putnam Cty.), Case No. 2022-CA-0357. Sadly, Johnson passed away in August 2024, as PLN reported. [See: PLN, Sep. 2024, p.9.]
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Related legal case
Human Rights Def. Ctr. v. Centurion of Fla. LLC
| Year | 2025 |
|---|---|
| Cite | Fla. 7th Jud. Cir. (Putnam Cty.), Case No. 2022-CA-0357 |
| Level | State Trial Court |
| Conclusion | Bench Verdict |