Georgia Department of Community Health v. Houston Hospitals, Inc.

CourtCourt of Appeals of Georgia
DecidedJune 27, 2024
DocketA24A0424
StatusPublished

This text of Georgia Department of Community Health v. Houston Hospitals, Inc. (Georgia Department of Community Health v. Houston Hospitals, Inc.) 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
Georgia Department of Community Health v. Houston Hospitals, Inc., (Ga. Ct. App. 2024).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, J.

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. https://www.gaappeals.us/rules

June 27, 2024

In the Court of Appeals of Georgia A24A0424. GEORGIA DEPARTMENT OF COMMUNITY HEALTH v. HOUSTON HOSPITALS, INC. A24A0425. COLISEUM MEDICAL CENTER, LLC v. HOUSTON HOSPITALS, INC. A24A0662. COLISEUM MEDICAL CENTER, LLC v. THE MEDICAL CENTER OF PEACH COUNTY, INC. A24A0664. GEORGIA DEPARTMENT OF COMMUNITY HEALTH v. MEDICAL CENTER OF PEACH COUNTY, INC. et al.

MCFADDEN, Presiding Judge.

These appeals challenge two separate superior court orders reversing the

Georgia Department of Community Health’s grant of a certificate of need allowing

Coliseum Medical Center, LLC to build a freestanding emergency department.

Because the superior courts correctly ruled that the Department had exceeded its

authority in granting the certificate of need to Coliseum, we affirm their orders. As detailed below, this is the second appearance of this matter before this court.

See Dept. of Community Health v. Houston Hosps., 365 Ga. App. 751 (880 SE2d 245)

(2022).

1. Background

Coliseum applied to the Department for a certificate of need to build a

freestanding emergency department in Houston County. The Department rendered

an initial decision granting the application and issuing a certificate of need to

Coliseum.

Several nearby hospitals, including Houston Hospitals, Inc. and the Medical

Center of Peach County, Inc., appealed the decision to the Certificate of Need Appeal

Panel, which is an independent agency. The Appeal Panel then assigned a hearing

officer. After an evidentiary hearing, the hearing officer reversed the Department’s

initial decision and denied Coliseum’s application for a certificate of need, finding,

among other things, that there were numerous existing alternatives to the proposed

freestanding emergency department and that the project would not have a positive

relationship to the existing healthcare delivery system.

2 Coliseum and the Department then appealed to the Department’s

commissioner. The commissioner reversed the hearing officer’s decision, modifying

various findings of fact and granting the certificate of need to Coliseum.

Houston Hospitals sought judicial review of the commissioner’s decision in the

Houston County Superior Court, and the Medical Center sought judicial review in the

Peach County Superior Court. Both superior courts reversed the commissioner’s

decision. Both courts held, among other things, that the commissioner exceeded his

authority to review the hearing officer’s findings of fact. In modifying the hearing

officer’s findings of fact, the superior courts held, the commissioner failed to comply

with the statutory requirements that he state with particularity that such findings were

not based on any competent substantial evidence.

This court granted discretionary review of the superior court orders, and the

Department and Coliseum appealed. The cases were consolidated for our review, and

we issued a decision. Dept. of Community Health v. Houston Hosps., supra. In that

decision, we held that

the commissioner violated OCGA § 31-6-44 (k) (1) and exceeded the scope of his statutory authority by failing to find, with particularity, in his written order that any rejected or modified findings of fact by the hearing officer were unsupported by competent substantial evidence. He further

3 violated the same statute by repeatedly basing his rejection of the hearing officer’s factual findings on the rejection of his legal conclusions.

Id. at 777 (V) (3). We vacated the superior court orders and remanded the cases with

direction that both courts vacate the commissioner’s decision and remand the case to

the Department for further consideration of Coliseum’s certificate of need application

in a manner consistent with our opinion. Id. at 777-778 (V) (3), (VI).

On remand, the commissioner again reversed the hearing officer’s decision and

approved Coliseum’s certificate of need request. Upon judicial review, both the

Houston County Superior Court and the Peach County Superior Court reversed the

commissioner’s remand decision, holding that the commissioner had again failed to

follow the statutory requirements concerning review of the hearing officer’s findings

of fact.

We granted applications for discretionary review of the two superior court

orders, and these appeals followed. In Case Nos. A24A0424 and A24A0425, the

Department and Coliseum, respectively, appeal from the Houston County order. And

in Case Nos. A24A0662 and A24A0664, they appeal from the Peach County order.

Case No. A24A0424

2. Modified findings of fact

4 The Department contends that the Houston County Superior Court erred in

determining that the commissioner had improperly modified the hearing officer’s

findings of fact. We disagree.

After our prior decision in this case, the Georgia Supreme Court issued its

decision in Vantage Cancer Centers of Ga. v. Dept. of Community Health, 318 Ga. 361

(898 SE2d 462) (2024), explaining the commissioner’s limited authority over a

hearing officer’s findings of fact in a contested certificate of need case.

[W]hen a case is contested, it is the hearing officer, rather than the agency, that is tasked with evaluating the evidence. . . . In contested [certificate of need] cases, after the Department’s staff makes its initial decision, see OCGA § 31-6-43 (b), the hearing officer conducts the full evidentiary hearing de novo, see OCGA § 31-6-44 (f), and OCGA § 31-6-44 (a) provides that the purpose of a panel of hearing officers shall be to serve as a panel of independent hearing officers to review the department’s initial decision to grant or deny a certificate of need application. After the evidentiary hearing, the hearing officer, not the [c]ommissioner, evaluates the evidence and makes written findings of fact and conclusions of law. OCGA § 31-6-44 (i). . . . [T]he [c]ommissioner plays no role in the evidentiary hearing under OCGA § 31-6-44[.]

Id. at 372 (2) (b) (punctuation omitted).

The commissioner, however, reviews the hearing officer’s decision on appeal,

and in doing so, “OCGA § 31-6-44 (k) (1) requires the [c]ommissioner to accept the

5 hearing officer’s findings of fact ‘unless the commissioner first determines from a

review of the entire record, and states with particularity in the order, that the findings

of fact were not based upon any competent substantial evidence.’” Vantage, supra at 367

(2) (emphasis supplied). The term “competent substantial evidence”

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