Skagit County Public Hospital District No. 304 v. Skagit County Public Hospital District No. 1, 305 P.3d 1079

Skagit Valley Hospital (Skagit Valley, PHD No. 1) acquired a medical practice (SVMC) that included a clinic (Unit 2) physically located inside United General Hospital’s (United General, PHD No. 304) district.
United General opposed the acquisition and claimed Skagit Valley needed its permission to operate within United General’s boundaries; Skagit Valley proceeded to operate the clinic.
United General sued in Snohomish County Superior Court seeking declaratory relief, a writ of prohibition, and injunctive relief; the trial court issued a writ of prohibition (stayed pending appeal).
The Supreme Court reviewed (direct appeal) whether a rural public hospital district (PHD) may provide services within another rural PHD’s territory without permission, and whether the writ was proper because alternative legal remedies existed.
The majority held rural PHDs may not operate in another rural PHD’s territory without permission and affirmed the writ, finding no plain, speedy, and adequate legal remedy; the dissent would reverse on both procedural and statutory grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a rural PHD provide medical services inside another rural PHD without permission?	United General: No — another district’s permission is required to protect local planning, revenue, and noncompetitive rural policy.	Skagit Valley: Yes — RCW 70.44.060(3) broadly authorizes providing services outside district boundaries; statute is plain.	Held: No — under the statutory scheme and legislative intent, a rural PHD may not operate within another rural PHD’s territory without that district’s permission.
Was there a plain, speedy, and adequate remedy in the course of legal procedure (writ proper)?	United General: Writ appropriate because other remedies would not be plain, speedy, and adequate to prevent territorial invasion and revenue harm.	Skagit Valley: Trial court abused discretion — United General could pursue injunction, declaratory relief, damages, and appeal.	Held: Trial court did not abuse its discretion; under these facts the writ was proper because alternative remedies were not adequate.

Alderwood Water Dist. v. Pope & Talbott, Inc., 62 Wn.2d 319 (analogizing water-district boundary rule to PHDs)
Kreidler v. Eikenberry, 111 Wn.2d 828 (standards for issuing writs of prohibition)
Dep’t of Ecology v. Campbell & Gwinn, LLC, 146 Wn.2d 1 (statutory interpretation de novo; consider statute as a whole)
Winsor v. Bridges, 24 Wash. 540 (statutory writ of prohibition reaches executive and administrative acts)
Okeson v. City of Seattle, 150 Wn.2d 540 (governmental vs. proprietary functions analysis)