& SC15-2292 Venice HMA, LLC d/b/a Venice Regional Medical Center v. Sarasota County and Sarasota Doctors Hospital, Inc. v. Sarasota County
228 So. 3d 76
Fla.2017Background
- Sarasota County’s public hospital district was created by special act (1949) and amended in 1959 to require the County to reimburse the district and any other Sarasota County hospital for indigent care.
- The 1959 indigent-care provision was carried forward (with minor changes) into a 2003 codifying special act; notice requirements for the 2003 act were met.
- Beginning in 2008 private hospitals in Sarasota submitted monthly claims to the County seeking reimbursement under the special act; the County refused to pay.
- Private hospitals sued for a declaration of their right to reimbursement; the trial court granted summary judgment for the County, finding the provision unconstitutional.
- The Second District affirmed, holding the special-law provision unconstitutionally granted a privilege to private corporations by benefiting Sarasota private hospitals but not private hospitals elsewhere.
- The Florida Supreme Court granted review and reversed, holding the indigent-care provision applies to all Sarasota hospitals (public and private) and does not grant a forbidden privilege to a private corporation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sarasota special-law indigent-care reimbursement grants a prohibited "privilege" to private corporations under art. III, § 11(a)(12) | Private hospitals: provision applies equally to all Sarasota hospitals, public and private, so it does not single out private corporations | County: provision gives private Sarasota hospitals an advantage over private hospitals elsewhere in Florida, so it grants a forbidden privilege | Held for plaintiffs: no unconstitutional privilege because the law benefits all hospitals within Sarasota County (public and private) |
| Proper comparison group for privilege analysis — county-level or statewide? | Private hospitals: compare only entities within Sarasota County because the law is a local special law | County: compare similarly situated hospitals statewide to detect unequal treatment | Held: comparison limited to the local subdivision affected; special/local law by definition operates only in that subdivision, so privilege must be assessed within that locality |
| Whether the special act impermissibly infringes county home-rule because not voter-approved (as county asserts) | Private hospitals/District: not an issue because original provision predates current home-rule constitutional text and was properly preserved/re-enacted | County: argues home-rule/approval issues render the provision invalid | Held: provision valid — preserved by continuous operation and properly reenacted in 2003; home-rule argument rejected |
| Whether Lawnwood precedent mandates invalidation because it struck a local law benefiting private hospitals in St. Lucie County | Private hospitals: Lawnwood is distinguishable because that act expressly targeted privately owned hospitals (a private-corporation class) | County: Lawnwood requires invalidation because local-law financial benefit to private hospitals is a prohibited privilege | Held: Lawnwood distinguished — there the law affected only private hospitals (a class); here the law benefits both public and private hospitals in the county, so it does not single out private corporations |
Key Cases Cited
- City of Fort Lauderdale v. Dhar, 185 So.3d 1232 (Fla. 2016) (statutory constitutionality is reviewed de novo)
- Pub. Defender, Eleventh Jud. Cir. v. State, 115 So.3d 261 (Fla. 2013) (facial unconstitutionality requires no set of circumstances in which statute is valid)
- Florida Dep’t of Bus. & Prof'l Reg. v. Gulfstream Park Racing Ass’n, 967 So.2d 802 (Fla. 2007) (defines "special" and "local" laws and distinguishes them from general laws)
- Lawnwood Medical Center, Inc. v. Seeger, 990 So.2d 503 (Fla. 2008) (broad reading of "privilege"; invalidated local law that expressly affected only privately owned hospitals)
- McKibben v. Mallory, 293 So.2d 48 (Fla. 1974) (repeal and substantial reenactment treated as continuous operation)