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The U.S. Court of Appeals for the Eleventh Circuit, narrowly applying the definition of “professional services” determined that the services provided by an individual presenting himself as a counselor did not constitute “professional services. The case is Chapman v. Ace Am. Ins. Co., No. 18-12972, 2019 U.S. App. LEXIS 15013 (11th Cir. May 21, 2019).

Mark and Barbara Chapman (the Chapman’s) had a ten-year-old son, Gregory, who was diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) and had a history of behavioral problems, most severely stealing and a self-inflicted gunshot wound to the leg. The Chapman’s received a referral from the Department of Children and Family Services and engaged Robert Taylor to provide mental health counseling services to Gregory. Taylor counseled Gregory for 5 months, between January and May 1998. In May 1998 Gregory committed suicide.

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