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Yakima Valley Memorial Hospital v. Washington State Department of Health

654 F.3d 919 (2011)

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Yakima Valley Memorial Hospital v. Washington State Department of Health

United States Court of Appeals for the Ninth Circuit

654 F.3d 919 (2011)

Facts

In 1974 Congress passed the National Health Planning and Resources Development Act, which required that states implement certificate-of-need programs. Under such programs, healthcare providers had to be preapproved by the state before establishing a facility or offering a certain service. In 1986 Congress repealed the National Health Planning and Resources Development Act without providing a savings clause. In 2007 the state of Washington passed a law establishing a certificate-of-need program for elective percutaneous coronary interventions (PCIs). The Washington State Department of Health (the department) (defendant) promulgated regulations under which certificates were issued based on the number of procedures a hospital was likely to perform and on geographic need. The Yakima Valley Memorial Hospital (the hospital) (plaintiff) was unable to qualify for a certificate of need and sued the department in federal district court. The hospital argued that the PCI certificate-of-need program violated the Commerce Clause in Article I of the United States Constitution. The hospital argued that the PCI certificate-of-need program created an unreasonable burden on interstate commerce by affecting the hospital’s ability to serve out-of-state patients and hire out-of-state doctors. The hospital also alleged that the program violated antitrust restraint-of-trade laws under the Sherman Act. The department moved to dismiss on the grounds of standing and failure to state a claim. The district court found that the hospital had standing but failed to state a claim under the Commerce Clause and the Sherman Act. In analyzing the Commerce Clause challenge, the district court held that Congress had authorized certificate-of-need programs. The hospital appealed.

Rule of Law

Issue

Holding and Reasoning (Fisher, J.)

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