St. Vincent's Center v. Memorial Healthcare
967 So.2d 794, 2007 Fla. LEXIS 1595, 32 Fla. L. Weekly Supp. 556 (2007)
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Rule of Law:
A statute written in general terms is an unconstitutional special law if its classification scheme is so narrowly drawn and time-limited that there is no reasonable possibility it could apply to any entity other than the single one it was designed to benefit.
Facts:
- St. Luke's Hospital, which had an open-heart surgery program and a 'closed-staff' personnel model, sought state permission to relocate its existing hospital to a new facility in Jacksonville.
- Concurrently, St. Vincent's Medical Center sought permission to establish a new hospital with an open-heart surgery program in the facility that St. Luke's planned to vacate.
- Under existing state law, establishing a new open-heart surgery program required a Certificate of Need (CON).
- The Florida Legislature enacted section 408.036(3)(l), which created a temporary exemption from the CON requirement for certain adult open-heart surgery programs.
- The statute's exemption criteria required that a new hospital be established in the location of an existing hospital with an open-heart program, that the existing hospital was relocating to a replacement facility using a 'closed-staff model,' and that the prior hospital performed more than 300 open-heart procedures annually.
- This new statutory exemption was set to be automatically repealed on January 1, 2008.
Procedural Posture:
- Memorial Healthcare Group, Inc. filed a complaint against the Agency for Health Care Administration in a Florida circuit court (trial court), seeking a declaratory judgment that the statute was unconstitutional.
- St. Vincent's Medical Center, Inc. intervened in the lawsuit to defend the statute.
- Following a non-jury trial, the circuit court found the statute to be an unconstitutional special law passed in the guise of a general law.
- St. Vincent's, as appellant, appealed the trial court's decision to the Florida First District Court of Appeal (intermediate appellate court).
- The First District Court of Appeal affirmed the circuit court's judgment.
- The Supreme Court of Florida accepted the appeal because the district court's decision declared a state statute invalid.
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Issue:
Does a state statute that creates a temporary exemption from a hospital Certificate of Need requirement violate the Florida Constitution's prohibition against special laws enacted in the guise of a general law when its highly specific criteria and sunset provision make it practically impossible for any hospital other than a single, specific one to qualify?
Opinions:
Majority - Anstead, J.
Yes, the statute is an unconstitutional special law enacted in the guise of a general law. A statute violates the Florida Constitution's prohibition on special laws if its highly specific criteria, combined with a short sunset provision, create a classification for which there is no reasonable possibility of new members. The court adopted the 'reasonable possibility' standard, rejecting a test based on mere theoretical or speculative possibility. Based on competent, substantial evidence from the trial court, the complex and unusual requirements of section 408.036(3)(l) were tailored precisely to the transaction between St. Vincent's and St. Luke's. The court found that the trial court correctly concluded there was no reasonable or practical possibility that any other hospital could meet the statute's criteria before its expiration, rendering it a special law passed without the constitutionally required notice.
Analysis:
This decision, along with its companion case Gulfstream Park, solidifies the 'reasonable possibility' test for distinguishing between permissible general laws and unconstitutional special laws in Florida. It signals that courts will engage in a practical, realistic inquiry into a statute's real-world effect, rather than accepting its facial neutrality. The ruling prevents the legislature from circumventing the constitutional requirements for passing special laws (e.g., public notice) through clever or hyper-specific drafting. This strengthens judicial oversight of the legislative process and ensures that laws intended to benefit a single entity are subjected to the heightened scrutiny the constitution demands.
