Mercy Hospitals East Communities v. Missouri Health Facilities Review Committee, 362 S.W.3d 415

Missouri CON law (Sections 197.300-197.366) conditions new facility construction on a certificate of need (CON).
MHFRC promulgated New Hospital Rule 19 CSR 60-50.400(6)(F)(l) exempting sub-$1 million new hospitals from CON.
April 2010, Patients First sought a non-applicability CON letter for a three-bed facility (~$953,750).
St. John's Mercy Health System sued for declaratory judgment challenging the New Hospital Rule and sought to enjoin its application.
Trial court dismissed for lack of justiciability but analyzed merits and held the Rule within authority.
On appeal, court held the case ripe, St. John's had standing, and the New Hospital Rule is valid; judgment affirmed as modified.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the suit is ripe and justiciable.	St. John's claim is ripe once the Rule applied to Patients First.	Not ripe until MHFRC decision or application.	Ripe; court reviews merits.
Whether St. John's has standing to challenge the rule.	St. John's is an economic competitor harmed by exemptions.	Standing arises under 536.053 for challenge to agency rules.	St. John's has standing.
Whether the New Hospital Rule is validly promulgated and consistent with CON Law.	Rule conflicts with CON Law by exempting under $1M.	Statutes not in conflict; legislative history supports rule.	New Hospital Rule valid; consistent with CON Law.

Missouri Bankers Ass'n v. Dir. of the Missouri Div. of Credit Unions, 126 S.W.3d 360 (Mo. banc 2003) (standing to challenge agency rules as economic competitor)
Barron v. Shelter Mut. Ins. Co., 220 S.W.3d 746 (Mo. banc 2007) (ripeness and justiciability for declaratory actions)
Foremost-McKesson, Inc. v. Davis, 488 S.W.2d 193 (Mo. banc 1972) (general standard for validity of administrative rules)