Sarasota County Public Hospital v. Department of Health
District Court of Appeal of Florida
553 So. 2d 189 (1989)
Memorial Hospital (plaintiff) and Doctors Hospital both applied to the state health agency (HRS) (defendant) to build competing acute-care hospital facilities in Sarasota offering similar services in close proximity; HRS issued a notice of intent to approve Doctors Hospital's application and deny Memorial's, reasoning Memorial's proposed facility would be costly and would duplicate Doctors Hospital's services. Memorial petitioned for a formal hearing to obtain a comparative review of both applications, but HRS dismissed the petition, and Memorial appealed.
Whether an administrative agency may deny one of two mutually exclusive applications for administrative approval without providing a formal hearing on both.