State of Florida, Department of Health v. Bayfront HMA Medical Center, LLC etc.
236 So. 3d 466
| Fla. Dist. Ct. App. | 2018Background
- Bayfront operates a Level II trauma center in Trauma Service Area (TSA) 9; Northside submitted a letter of intent and later an application to become a trauma center in TSA 9.
- Florida law establishes a multi-stage trauma application process: LOI, provisional review (eligibility to begin provisional operation after April 30), onsite review, and final verification with a statutory timeline. TSA 9 is allocated two trauma-center positions by rule.
- Bayfront sued the Department of Health and Northside seeking injunctive and declaratory relief, arguing the Department lacked authority to accept/review/provisionally approve an application when no open slot exists and that Northside could not begin provisional operations while administrative challenges were pending.
- The trial court granted a temporary injunction preventing Northside from provisionally operating and enjoining the Department from permitting provisional operation pending administrative/judicial review, finding Bayfront likely to succeed on the merits and to suffer irreparable harm.
- On appeal, the First DCA reversed: it held the statutory scheme requires the Department to accept LOIs and provisionally review applications without considering need until the onsite review stage, and Bayfront failed to prove both a substantial likelihood of success and irreparable harm required for a temporary injunction.
Issues
| Issue | Plaintiff's Argument (Bayfront) | Defendant's Argument (Dept./Northside) | Held |
|---|---|---|---|
| Whether the Department may accept/review/provisionally approve applications when there is no open trauma-center slot (need) in the TSA | Statute and rules prohibit provisional acceptance/granting absent an available slot; need must be considered before provisional approval | Statute requires the Department to accept LOIs and provisionally review applications without regard to need; need is considered later at onsite/final selection | Reversed trial court: Department may accept and provisionally review/applicants without considering need until onsite review; Bayfront not substantially likely to prevail |
| Whether a provisional trauma center may begin operations while administrative challenges to provisional approval are pending | Northside should be barred from beginning provisional operations until administrative and judicial review conclude | Statute permits provisional operation after provisional review (post-April 30); nothing in statute mandates automatic stay pending administrative challenge; staying operations would disrupt statutory timeline and viability | Reversed trial court: Bayfront’s claim that provisional operations must be stayed pending administrative review is only colorable, not substantially likely to succeed |
| Whether Bayfront demonstrated irreparable harm warranting a temporary injunction | Opening Northside would cause irreparable harms: dilution of trauma patients, staffing losses, skill degradation, and decreased care quality | Alleged harms are speculative or economic (compensable by damages); evidence did not show likely destruction of Bayfront’s business or quality decline | Reversed trial court: Bayfront failed to show irreparable harm (harms speculative, economic, unsupported by competent substantial evidence) |
| Standard and burden for preliminary injunction | N/A — Bayfront must prove four elements with competent substantial evidence | N/A — Appellate court reviews factual findings for abuse of discretion and legal conclusions de novo | Court reaffirmed that movant must prove all four elements; Bayfront failed on likelihood of success and irreparable harm |
Key Cases Cited
- Gainesville Woman Care, LLC v. State, 210 So. 3d 1243 (Fla. 2017) (standard of review for temporary injunctions and elements required)
- Dep’t of Revenue v. Graczyk, 206 So. 3d 157 (Fla. 1st DCA 2016) (agency statutory interpretation entitled to deference)
- City of Jacksonville v. Naegele Outdoor Advert. Co., 634 So. 2d 750 (Fla. 1994) (definition and proof required for substantial likelihood of success on merits for preliminary injunction)
- U.S. 1 Office Corp. v. Falls Home Furnishings, Inc., 655 So. 2d 209 (Fla. 3d DCA 1995) (business-destruction exception to irreparable-harm rule)
- Jacksonville Elec. Auth. v. Beemik Builders & Constructors, Inc., 487 So. 2d 372 (Fla. 1st DCA 1986) (injury that is doubtful or speculative cannot support irreparable harm)
- Agency for Health Care Admin. v. Cont’l Car Servs., Inc., 650 So. 2d 173 (Fla. 2d DCA 1995) (economic loss ordinarily does not constitute irreparable harm)