Fletcher Hosp., Inc. v. N.C. Dep't of Health & Hum. Servs.

CourtCourt of Appeals of North Carolina
DecidedMarch 4, 2026
Docket25-658
StatusUnpublished
AuthorJudge John Arrowood

This text of Fletcher Hosp., Inc. v. N.C. Dep't of Health & Hum. Servs. (Fletcher Hosp., Inc. v. N.C. Dep't of Health & Hum. Servs.) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fletcher Hosp., Inc. v. N.C. Dep't of Health & Hum. Servs., (N.C. Ct. App. 2026).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-658

Filed 4 March 2026

Office of Administrative Hearings, No. 22DHR02385

FLETCHER HOSPITAL INC. d/b/a ADVENTHEALTH HENDERSONVILLE, Petitioner,

v.

NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES, DIVISION OF HEALTH SERVICE REGULATION, HEALTH CARE PLANNING AND CERTIFICATE OF NEED SECTION, Respondent,

And

MH MISSION HOSPITAL, LLLP, Respondent-Intervenor.

Appeal by petitioner from final decision on remand entered 7 March 2025 by

Administrative Law Judge David F. Sutton in the Office of Administrative Hearings.

Heard in the Court of Appeals 10 February 2026.

Wyrick Robbins Yates & Ponton LLP, by Charles George, Frank S. Kirschbaum, and Trevor Presler, for Petitioner-appellant.

Attorney General Jeff Jackson, by Special Deputy Attorney General Derek L. Hunter, for Respondent-appellee.

Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C., by Iain M. Stauffer and William F. Maddrey, for Respondent-intervenor-appellee. FLETCHER HOSP., INC. V. N.C. DEP’T OF HEALTH & HUM. SERVS.

Opinion of the Court

ARROWOOD, Judge.

Fletcher Hospital, Inc. d/b/a AdventHealth Hendersonville (“AdventHealth”)

appeals from a final decision on remand from this Court granting summary judgment

to North Carolina Department of Health and Human Services, Division of Health

Service Regulation, Healthcare Planning and Certificate of Need Section (“DHHS”)

and MH Mission Hospital, LLLP (“Mission”). For the following reasons, we affirm

the final decision.

I. Background

In February 2022, Mission filed a non-competitive application for a Certificate

of Need (“CON”) to build a freestanding emergency department (“FSED”) in Candler,

North Carolina. Due to public health concerns related to the COVID-19 pandemic,

DHHS did not hold an in-person public hearing on Mission’s CON application.

Instead, DHHS accepted written comments regarding the applications.

AdventHealth filed written comments in opposition to Mission’s application.

Members of the public also filed comments both in support of and in opposition to

Mission’s application. Following its review of the application and written comments,

DHHS conditionally approved Mission’s CON application on 24 May 2022.

AdventHealth filed a Petition for Contested Case Hearing on 23 June 2022

contesting DHHS’s conditional approval of Mission’s CON application. On

17 March 2023, the Administrative Law Judge (“ALJ”) granted summary judgment

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in favor of AdventHealth. The ALJ concluded that DHHS erred by failing to hold in-

person hearings and that AdventHealth’s rights were substantially prejudiced by

that error as a matter of law. Mission and DHHS appealed the ALJ’s decision to this

Court on 14 April 2023.

This Court considered Mission and DHHS’s appeal of the 17 March 2023

decision in Fletcher Hosp. Inc. v. N.C. Dep’t of Health & Hum. Servs., 293 N.C. App.

41 (2024) [hereinafter Fletcher I]. There, we explained that as the petitioner in a

contested case hearing, AdventHealth had the burden of separately establishing that

DHHS erred and that DHHS substantially prejudiced AdventHealth’s rights. Id. at

49–50. We held that AdventHealth successfully showed that DHHS erred by failing

to hold a public hearing on Mission’s CON application under N.C.G.S. § 131E-

185(a1)(2). Id. at 46–47. However, we also held that “substantial prejudice cannot

be presumed per se” and so AdventHealth had not yet met its burden to show

substantial prejudice. Id. at 50–51. We vacated the ALJ’s Order and remanded the

case for further proceedings. Id. at 51.

On remand, the ALJ reconsidered the parties’ motions for summary judgment.

AdventHealth offered additional evidence to show substantial prejudice including

findings in related disputes between the parties and testimony about the effect of

public hearings and the approval of Mission’s CON application. For example,

AdventHealth presented findings by ALJ Sutton in a separate proceeding which

stated that public hearings provide the opportunity “to speak directly to the analyst,

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express opinions that they may not be able to put as easily in writing, for DHHS to

ask questions and the public to demonstrate support or opposition to a project.”

AdventHealth also pointed to past decisions in which DHHS relied on public hearing

comments to determine conformity with CON requirements.

In a deposition, Graham Fields, the Assistant to the President of

AdventHealth, testified that had there been a public hearing he would have been

garnering support for the opposition and “making sure the community had ample

opportunity to share its thoughts.” He also testified that based on public

participation in past hearings for other medical centers, he expected that a public

hearing on Mission’s CON application would have brought in “a great number of

people” and raised “very serious concerns” for the project.

As to prejudice resulting from the approval of Mission’s CON Application,

AdventHealth presented evidence of how Mission’s FSED would interfere with

AdventHealth’s business and operations. AdventHealth projected that Mission’s

FSED in Candler would result in over $4 million in contribution margin losses from

lost patient admissions. Additionally, AdventHealth’s employees and expert

witnesses reported that the loss of revenue would force AdventHealth to discontinue

some of its unprofitable community benefit services including maternity and mental

health.

AdventHealth also offered evidence about the effects of Mission’s specific

practices and power. Evidence demonstrated that Mission has little competition for

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acute care services in Buncombe County, in part because it received a Certificate of

Public Advantage that exempted Mission from antitrust laws and allowed it to merge

with St. Joseph’s Hospital. In a letter opposing one of Mission’s other CON

applications, the Attorney General explained that Mission’s “lack of competition

harms residents of western North Carolina by increasing the cost, and reducing the

quality, of health care services in the region.” In a separate letter, the Attorney

General stated that they had received complaints that Mission charges high prices

and prohibits insurers from encouraging patients to receive care from less expensive

providers. As to how that affects AdventHealth, AdventHealth’s CEO stated that

Mission’s monopoly-like status gives them “levers that other entities do not have”

such as the ability to control the market on pay.

On 7 March 2025, ALJ Sutton entered a final decision granting summary

judgment in favor of DHHS and Mission. AdventHealth filed notice of appeal to this

Court on 7 April 2025.

II. Discussion

AdventHealth raises three issues on appeal: 1) whether the ALJ erred by not

considering if Mission’s and DHHS’s rights were substantially prejudiced by the

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Fletcher Hosp., Inc. v. N.C. Dep't of Health & Hum. Servs., Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-hosp-inc-v-nc-dept-of-health-hum-servs-ncctapp-2026.