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Sarasota County Public Hospital v. Department of Health
District Court of Appeal of Florida
553 So. 2d 189 (1989)
Sarasota County Public Hospital, which operated under the name Memorial Hospital (Memorial Hospital) (plaintiff), and HCA Doctors Hospital (Doctors Hospital) each filed certificate of need applications with the Department of Health and Rehabilitative Services (HRS) (defendant). Each hospital sought to construct acute care hospitals in the city of Sarasota. Memorial Hospital sought to construct a satellite hospital, while Doctors Hospital sought to construct a replacement hospital. Both hospitals sought to offer similar services within close proximity to each other. HRS issued notices of intent advising the hospitals that it would approve Doctors Hospital’s application and deny Memorial Hospital’s application. HRS reasoned that Memorial Hospital’s facility would be expensive to construct and could duplicate services provided by Doctors Hospital in the same vicinity. Memorial Hospital filed a petition for a formal administrative hearing to obtain a comparative review of the two applications. HRS dismissed the petition. Memorial Hospital appealed.
Rule of Law
Holding and Reasoning (Hall, J.)
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