Missouri Court of Appeals, Western District / Aug 2, 2022
Prime Healthcare Services-Kansas City, LLC, d/b/a St. Joseph Medical Center vs. State of Missouri Department of Health and Senior Services
Prime Healthcare Services-Kansas City, LLC, d/b/a St. Joseph Medical Center, appealed a judgment upholding the validity of the 15-mile rule, 19 C.S.R. § 30-40.430(1)(M), which prevented its designation as a level III trauma center. St. Joseph argued the rule was arbitrary and capricious under § 536.014(3) and an unconstitutional special law under article III, § 40(28) of the Missouri Constitution. The appellate court affirmed the trial court's judgment, concluding that the trial court's finding that the rule was not arbitrary and capricious was not against the weight of the evidence. The court also found that the rule had a rational basis and was therefore not an unconstitutional special law.