Doctors Hospital of Augusta, LLC v. Georgia Department of Community Health

CourtCourt of Appeals of Georgia
DecidedFebruary 14, 2018
DocketA17A1902
StatusPublished

This text of Doctors Hospital of Augusta, LLC v. Georgia Department of Community Health (Doctors Hospital of Augusta, LLC v. Georgia Department of Community Health) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doctors Hospital of Augusta, LLC v. Georgia Department of Community Health, (Ga. Ct. App. 2018).

Opinion

FIFTH DIVISION McFADDEN, P. J., RAY, and SELF, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

February 14, 2018

In the Court of Appeals of Georgia A17A1902. DOCTORS HOSPITAL OF AUGUSTA, LLC v. SE-009 GEORGIA DEPARTMENT OF COMMUNITY HEALTH, et al.

SELF, Judge.

Doctors Hospital of Augusta, LLC appeals from a superior court’s order

dismissing its petition for judicial review challenging the Georgia Department of

Community Health’s decision to grant a Certificate of Need (“CON”) to MCG Health,

Inc. d/b/a Georgia Regents Medical Center (“Georgia Regents”).1 Doctors Hospital

asserts that the trial court erred for numerous alternative reasons when it relied upon

the prior pending action doctrine to dismiss its case. For the reasons explained below,

we reverse.

1 The CON granted Georgia Regents the right to establish a new general acute care hospital in Columbia County, Georgia. We conduct a de novo review of a trial court’s order dismissing a case based

upon the prior pending action doctrine. Brock v. C & M Motors, 337 Ga. App. 288,

290 (1) (787 SE2d 259) (2016). Two portions of the Civil Practice Act are implicated

in this doctrine that “are closely related in effect and are to be considered and applied

together.” (Citation and punctuation omitted.) Id. OCGA § 9-2-5 (a) provides:

No plaintiff may prosecute two actions in the courts at the same time for the same cause of action and against the same party. If two such actions are commenced simultaneously, the defendant may require the plaintiff to elect which he will prosecute. If two such actions are commenced at different times, the pendency of the former shall be a good defense to the latter.

OCGA § 9-2-44 (a) states:

A former recovery or the pendency of a former action for the same cause of action between the same parties in the same or any other court having jurisdiction shall be a good cause of abatement. However, if the first action is so defective that no recovery can possibly be had, the pendency of a former action shall not abate the latter.

The purpose of the doctrine embodied in these statutes “is to ensure judicial economy,

to avoid inconsistent judgments, and to prevent harassment of the parties through

multiple proceedings.” (Citations and punctuation omitted.) Brock, 337 Ga. App. at

2 290 (1). But it can only be applied where the causes of action and the parties are the

same. Oskouei v. Orthopaedic & Spine Surgery of Atlanta, 340 Ga. App. 67, 69 (796

SE2d 299) (2017). Additionally, the rule does not apply “[i]f it appears from the face

of the pleadings in the first-filed case that the court therein does not have jurisdiction

to resolve the pending claims on the merits, then the . . . later-filed suit may proceed

forward.” (Citations omitted.) Bhindi Brothers v. Patel, 275 Ga. App. 143, 146 (619

SE2d 814) (2005). With these principles in mind, we turn to the procedural history

of this case.

On November 26, 2014, the Department of Community Health granted a CON

to Georgia Regents. Doctors Hospital, which had applied and competed for the same

CON, appealed the grant of the CON to the CON Appeal Panel.

On May 1, 2015, before the appeal panel could conduct a de novo evidentiary

hearing, Doctors Hospital and two physicians practice groups filed a petition in

Fulton County Superior Court seeking: (1) a declaratory judgment that a “county-

financed exception” regulation created by the Department of Community Health was

invalid; and (2) a writ of mandamus compelling the Commissioner of the Department

of Community Health to deny Georgia Regent’s CON application. The petition states

that Doctors Hospital had appealed the grant of the CON and that an administrative

3 hearing was scheduled to begin on June 22, 2015. In the mandamus portion of the

petition, Doctors Hospital alleged that “[t]he administrative review does not provide

an equally convenient, complete and beneficial relief to Doctors Hospital, as it cannot

consider the impact on Doctors Hospital as a property owner in Columbia County.”

On June 10, 2015, the Department of Community Health and its Commissioner

moved to dismiss the petition based upon a lack of subject matter jurisdiction, arguing

in their supporting briefs that the superior court lacked subject matter jurisdiction

because no exception to the administrative exhaustion requirement, a condition

precedent to suit, applied. They submitted no evidence in support of their legal

argument that a declaratory judgment action was improper while administrative

proceedings were in progress, and asserted that if “Doctors Hospital is aggrieved by

the administrative decision, it may petition for judicial review.”

On September 21, 2015, the superior court heard oral argument on the motion

to dismiss. On October 13, 2015, the superior court dismissed the declaratory

judgment action because it lacked subject matter jurisdiction based upon Doctors

Hospital’s failure to exhaust its administrative remedies and its lack of standing. On

November 12, 2015, Doctors Hospital filed a notice of direct appeal. This Court

dismissed the appeal on June 15, 2016, based upon Doctors Hospital’s failure to

4 follow the discretionary appeal procedures, and the Supreme Court denied Doctors

Hospital’s petition for a writ of certiorari on February 27, 2017.

Before the superior court entered its ruling on the motion to dismiss the

declaratory judgment action, the hearing officer in the administrative action issued

a decision on September 24, 2015, upholding the grant of a CON to Georgia Regents.

On November 23, 2015, the Department of Community Health adopted the findings

of the hearing officer and issued a final decision awarding the CON to Georgia

Regents.

On December 23, 2015, Doctor’s Hospital filed a second action in superior

court – a petition for judicial review of the final agency decision granting the CON.

In its enumerations of errors, it raised the same objections to the county-financed

exception it had raised in the declaratory judgment action, but also asserted that the

final decision was arbitrary and capricious, contained legal errors regarding existing

alternatives criteria, and misapplied regulatory text in the joinder considerations.

In January 2016, less than one month after the petition for judicial review had

been filed, Georgia Regents and the Department of Community Health moved to

dismiss the petition for judicial review of the agency decision based upon the prior

5 pending action doctrine.2 On March 21, 2016, the superior court held a hearing on the

motion to dismiss and took the issue under advisement. On April 13, 2016, it signed

an order granting the motion to dismiss that was prepared by counsel for Georgia

Regents and the Department of Community Health.

1. In our view, the trial court erred by finding that “the two pending actions

involve the same cause of action.” The stated rationale for this conclusion was that

the “primary and threshold argument” in the instant case is the invalidity of the

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Related

Bhindi Bros. v. Patel
619 S.E.2d 814 (Court of Appeals of Georgia, 2005)
Action Staffing v. Spalding Ford-Lincoln-Mercury
403 S.E.2d 61 (Court of Appeals of Georgia, 1991)
Brock v. C & M Motors, Inc.
787 S.E.2d 259 (Court of Appeals of Georgia, 2016)
Armin Oskouei v. Orthopaedic & Spine Surgery of Atlanta, LLC
796 S.E.2d 299 (Court of Appeals of Georgia, 2017)
Scott v. Rakestraw
556 S.E.2d 492 (Court of Appeals of Georgia, 2001)

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