Narrative Opinion Summary
Shands Jacksonville Medical Center, Inc. appeals the order approving Orange Park Medical Center, Inc.'s provisional trauma center application, raising three issues: 1. The need for the new trauma center should not be deferred until the final selection phase of the process. 2. The Department of Health operated under an unadopted rule. 3. The Department erred in allowing the new trauma center to commence operations before resolving Shands' administrative challenge. For the first issue, the court affirms the decision based on precedent from State, Dep't of Health v. Bayfront HMA Med. Ctr. LLC. For the second issue, the court also affirms, referencing State, Dep't of Health v. Shands Jacksonville Medical Center. The third issue is deemed moot. The court's decision results in a partial affirmation and a dismissal. Judges Wetherell, Makar, and Winsor concur.
Legal Issues Addressed
Premature Commencement of Operations Amid Administrative Challengessubscribe to see similar legal issues
Application: The challenge regarding the Department allowing the trauma center to operate before resolving Shands' administrative challenge was deemed moot by the court.
Reasoning: The Department erred in allowing the new trauma center to commence operations before resolving Shands' administrative challenge.
Timing of Need Assessment for Trauma Centerssubscribe to see similar legal issues
Application: The court affirmed that the need for a new trauma center can be assessed at the final selection phase, following precedent set in State, Dep't of Health v. Bayfront HMA Med. Ctr. LLC.
Reasoning: The need for the new trauma center should not be deferred until the final selection phase of the process.
Use of Unadopted Rules by Administrative Bodiessubscribe to see similar legal issues
Application: The court found that the Department of Health did not err in operating under an unadopted rule, as previously upheld in State, Dep't of Health v. Shands Jacksonville Medical Center.
Reasoning: The Department of Health operated under an unadopted rule.