When A Governmental Entity Is An Account Debtor, Can It Ignore A "Deflection Of Payment" Notice?

LexisNexis (November 20, 2017, 1:58 PM EST) -- Article 9 of the UCC codifies some ancient contract rules including the rule that, when a merchant assigns its accounts receivable to a factor, the account debtor must begin making payments directly to the factor if it receives a "deflection notice."  Failure to deflect payment to the factor can impose big-time liability on the account debtor.  But what if the account debtor is a governmental entity?  Is it immune from having to pay twice—once to the merchant assignor and then to the factor?  In a recent case from Florida, the court imposed double liability on a state agency (account debtor)  that ignored the factor's deflection notice. We think the decision is correct, and that a 2005 Ohio Supreme Court decision is wrong. ...