A recent court decision has significant implications for Caron Treatment Centers, as a judge denied the company’s motion for summary judgment in a case involving allegations of abuse and negligence. The ruling means that key factual disputes must now be resolved by a jury, rather than being dismissed by the court.

Overview

Plaintiffs, Denise and Francis Mann, seek damages in their action for wrongful death and medical negligence action against Caron Treatment Centers of Florida, Inc., d/b/a Caron Renaissance, a substance use treatment facility.[i] The litigation filed in the Palm Beach County Circuit Court (15^th Judicial District) arises from the death of their son, Nathan Mann, an 18-year-old with a documented history of co-occurring mental health and substance use disorders, who died after leaving the Caron Renaissance facility in September 2020.

Nathan, a Pennsylvania native and accomplished cellist, was admitted to Caron Renaissance in June 2020 following a 30-day inpatient program at Caron Pennsylvania.  His parents later had him transferred to one of Caron’s Florida treatment centers upon assurances that the Florida facility specialized in dual-diagnosis treatment and would support his transition to college.  Plaintiffs allege that Nathan’s condition deteriorated due to inadequate care.

Nathan died after leaving Caron’s Delray Beach facility in September 2020.  He was last seen on September 12, 2020, after he left the treatment facility in violation of his treatment orders. Caron allegedly failed to notify law enforcement promptly and allegedly provided inaccurate information to investigators. Nathan was struck and killed by a train on September 14, 2020.

An autopsy revealed the presence of alcohol, cocaine, and dextromethorphan (DXM), though the accuracy of the toxicology report is contested.

Key factual allegations by the plaintiffs include:

• Improper Medication Management: Discontinuation of ADHD medication despite neuropsychological confirmation of need; lack of coordination among providers.
• Inappropriate Therapeutic Practices: Use of confrontational group therapy and behavioral restrictions, including prolonged isolation.
• Suppression of Familial Support: Restricted parental contact and discouragement of advocacy.
• Neglect of Therapeutic Outlets: Limitation of access to music, a key emotional outlet for Nathan.
• Failure to Respond to Crisis Indicators: Ignored signs of acute psychological distress and physical symptoms prior to Nathan’s disappearance.

Legal Claims and Procedure

On August 23, 2023, Plaintiffs filed a detailed Second Amended Complaint.  In it the Plaintiffs assert the following causes of action:

• Medical Negligence: Failure to appropriately assess and treat Nathan’s mental health conditions.
• Negligent Hiring, Supervision, and Retention: Assignment of an unlicensed intern as primary therapist without disclosure.
• Breach of Fiduciary Duty: Misrepresentations regarding the scope and quality of care.
• Violation of Florida’s Vulnerable Adult Statute[ii]: Failure to protect a vulnerable adult from abuse, neglect, or exploitation.
• Failure to Follow Critical Incident Protocols: Including delayed law enforcement notification and miscommunication with family.

On July 6, 2025, the Court denied Caron’s motion for summary judgment on causation and foreseeability. More recently, on July 14, 2025, the Court denied Caron’s motions for summary judgment on all vicarious liability claims and negligent hiring/supervision.  The Court also denied Caron’s motion for partial summary judgment on the affirmative defense under Florida’s alcohol or drug defense statute.

The denial of summary judgment significantly increases Caron’s legal exposure. The company now faces potential liability on multiple fronts:

• Vicarious liability for the actions of its employees.
• Direct liability for alleged negligent hiring and supervision practices.
• Statutory liability under Florida’s Vulnerable Adult Act, which allows for punitive damages in cases of abuse or neglect.[iii]

The case is scheduled for trial in Summer 2025. The court’s recent rulings have cleared the path for the plaintiffs to present their claims to a jury. This development strengthens the plaintiffs’ position and may increase pressure on Caron to consider settlement options before trial. The trial is expected to address critical issues surrounding the standard of care in dual-diagnosis treatment settings and the responsibilities of behavioral health providers toward vulnerable young adults.

Broader Implications for Healthcare and Rehabilitation Facilities

Beyond the immediate legal consequences for Caron, the ruling serves as a cautionary signal to other healthcare and rehabilitation providers. It underscores the heightened duty of care owed to vulnerable patients, particularly those dealing with mental health or substance use disorders.

For health care and rehab facilities, the case highlights the importance of rigorous hiring and credentialing practices.  Additionally, providers may wish to prioritize effective supervision, especially when unlicensed staff are involved in patient care. Moreover, care facilities may need to revisit their protocols for handling unauthorized patient flight, internal incident reporting, and coordination with law enforcement.

Facilities across the sector may need to re-evaluate their operational procedures to mitigate similar risks and ensure compliance with legal and ethical standards.

If you have questions about this matter or other legal considerations for health care facilities or rehabilitation centers offering in-patient mental health treatment, please contact the author Julie Noonan at jnoonan@tysonmendes.com.

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Sources

[i] Mann v. Caron of Florida, Inc., 2023-CA-009963; Palm Beach Cnty. Circuit Court (15^th Circ.).

[ii] Fla. Stat. § 415.1111

[iii] Fla. Stat. § 415.1111.