Ex parte Alabama State Health Planning and Development Agency.

The Alabama State Health Planning and Development Agency ("SHPDA") granted HealthSouth of Alabama, LLC ("HealthSouth") a certificate of need ("CON") allowing HealthSouth to operate 17 inpatient physical-rehabilitation beds in Shelby County. In a separate proceeding, SHPDA granted another CON to HealthSouth allowing it to operate an additional 17 inpatient physical-rehabilitation beds in Shelby County. Shelby Ridge Acquisition Corporation d/b/a Shelby Ridge Rehabilitation Hospital ("Shelby Ridge") opposed HealthSouth's CON applications, and, after SHPDA issued the CONs to HealthSouth, Shelby Ridge appealed SHPDA's decision. The circuit court reversed one of SHPDA's decisions but affirmed the other. HealthSouth, SHPDA, and Shelby Ridge appealed separately to the Court of Civil Appeals, which consolidated the appeals and concluded that SHPDA had erred by granting the CONs to HealthSouth. HealthSouth and SHPDA separately petitioned the Supreme Court for review, which was granted. While the appeals were pending, the parties resolved their disputes; the parties agreed that HealthSouth should have been allowed to build the planned 34-bed physical-rehabilitation hospital in Shelby County. The parties also agreed that the Court of Civil Appeals wrongly decided the appeals before it insofar as HealthSouth's CON applications were concerned. The Supreme Court agreed that the Court of Civil Appeals erred. "It is sufficient to note that the pivotal error of that court's opinion is the characterization as 'key' and determinative two of the many considerations to be evaluated and balanced by SHPDA in considering CON applications." The Supreme Court reversed the Court of Civil Appeals and rendered judgment in favor of HealthSouth and SHPDA. The Supreme Court also remanded the cases to the Court of Civil Appeals with instructions that that court remand the cases to the circuit court so the parties could implement the resolution they reached. View "Ex parte Alabama State Health Planning and Development Agency." on Justia Law