Washington State Hospital Association v. Washington State Department of Health

183 Wn.2d 590, 353 P.3d 1285 (2015) · Supreme Court of Washington · July 9, 2015 · No. No. 90486-3

Summary

The Washington Supreme Court held that the Washington State Department of Health exceeded its statutory authority by adopting a rule broadly defining hospital ownership changes subject to certificate-of-need review. The rule covered any direct or indirect change in control, including changes in stock ownership or a hospital board of directors, beyond the statutory terms sale, purchase, or lease. The court affirmed the invalidation of the rule.

Holdings

  1. The Department of Health exceeded its statutory authority because its rule defining "sale, purchase, or lease" to include any transaction producing a direct or indirect change in hospital control was too broad and inconsistent with RCW 70.38.105(4)(b). The rule was therefore invalid.

Questions Presented

  1. Whether the Department of Health exceeded its statutory authority by promulgating a rule defining "sale, purchase, or lease" of a hospital to include any direct or indirect change in control.
  2. Whether the Department's New Rule was invalid under the Washington Administrative Procedure Act because it was inconsistent with RCW 70.38.105(4)(b).

Disposition

affirmed

Cases Cited (13)

  • University of Washington Medical Center v. Department of Health, 164 Wn.2d 95, 100, 187 P.3d 243 (2008)(followed)
  • Tapper v. Employment Security Department, 122 Wn.2d 397, 402, 858 P.2d 494 (1993)(followed)
  • Macey v. Department of Employment Security, 110 Wn.2d 308, 312, 752 P.2d 372 (1988)(followed)
  • State v. Wentz, 149 Wn.2d 342, 346, 68 P.3d 282 (2003)(followed)
  • City of Pasco v. Public Employment Relations Commission, 119 Wn.2d 504, 507, 833 P.2d 381 (1992)(followed)
  • St. Francis Extended Health Care v. Department of Social & Health Services, 115 Wn.2d 690, 702, 801 P.2d 212 (1990)(followed)
  • Department of Labor & Industries v. Gongyin, 154 Wn.2d 38, 50, 109 P.3d 816 (2005)(followed)
  • Washington Public Ports Association v. Department of Revenue, 148 Wn.2d 637, 646, 62 P.3d 462 (2003)(followed)
  • Department of Ecology v. Campbell & Gwinn, LLC, 146 Wn.2d 1, 19, 43 P.3d 4 (2002)(followed)
  • Department of Ecology v. Theodoratus, 135 Wn.2d 582, 600, 957 P.2d 1241 (1998)(followed)

Showing top 10 of 13.

Cited In (0)

No citing cases on record yet.

Download CaseDownload Case DataDownload Case and DataDownload AI Instructions

Court Document

Open PDF
Loading document…

More from Washington Supreme Court