Sarasota Doctors Hospital, Inc. v. Sarasota County (consolidated with Venice HMA, LLC v. Sarasota County)
Private hospitals sued Sarasota County for declaratory relief seeking reimbursement of indigent-care costs mandated by a special act; the trial court held sovereign immunity barred the claims and, alternatively, that the hospitals failed to comply with the act. The Second DCA reversed the sovereign immunity ruling, holding that sovereign immunity does not apply at all to claims premised on a governmental actor's ultra vires conduct or refusal to obey a direct legislative mandate, but affirmed the finding that the hospitals failed to submit timely certified lists with 'itemized charges' as the special act required.
Key facts
- Sarasota Doctors Hospital, Inc. and Venice HMA, LLC sued Sarasota County seeking declaratory relief and reimbursement of indigent-care costs mandated by a special act.
- The trial court dismissed the claims on sovereign immunity grounds and alternatively found the hospitals failed to comply with the special act's requirements for timely submission of certified lists with itemized charges.
- +2 more key facts with a free trial
Why it matters
This is an unusually thorough Second DCA exposition of the boundary between sovereign immunity's inapplicability and its waiver, giving litigators a roadmap for suing government entities that refuse to follow mandatory… — full analysis with a trial
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