Lawnwood Med. Ctr., Inc. v. Seeger

Board of Directors Authority

Lawnwood Med. Ctr., Inc. v. Seeger, No. SC07-1300 (Fla. Aug. 28, 2008)

The Supreme Court of Florida affirmed the appellate court and held that a county hospital governance law granted a privilege to a private corporation and, consequently, violated the state’s constitutional prohibition against such an outcome. A “privilege” is a special advantage, benefit or right given. After several disputes with its medical staff, Lawnwood Medical Center (LMC) sought relief from the Florida legislature. The legislature, in turn, enacted a law which only affected LMC’s two hospital facilities. Because the law afforded LMC power in running the hospital outside the usual boundaries of authority, the court concluded that the law granted the hospital a privilege in violation of the state’s constitution. The court also determined that portions of the law could not be preserved by the severability doctrine, considering the statutory scheme was “replete with special benefits and advantages granted to [the hospital].”