Englewood Hospital & Medical Center v. the State of New Jersey

Syllabus

Plaintiff hospitals brought action challenging the charity care program that requires them to provide care to all patients regardless of their ability to pay, while also prohibiting them from billing patients who qualify for charity care under the statute. The trial court dismissed certain hospitals' claims for failure to exhaust administrative remedies. As to the remaining claims, the trial court found that the regulations do not affect a constitutional taking under either a per se or analysis. On de novo review, the court first addressed the ripeness issue. It held that plaintiffs raised facial challenges to charity care and therefore had properly raised their claims in the first instance with the trial court. Therefore, the court considered all plaintiff hospitals' constitutional takings claims. Next, the court held that plaintiffs failed to show either a per se or regulatory taking violative of the Fifth and Fourteenth Amendments of the United States Constitution as well as Article I, Paragraph 20 of the New Jersey Constitution. As a result, the court affirmed the trial court's order granting summary judgment on the merits, but did so on different grounds, entering summary judgment against all plaintiffs, including those previously dismissed for failure to exhaust administrative remedies.