The Court of Appeals of Tennessee ruled that the Putnam County chancery court had the authority to hear a case challenging the Tennessee Health Facilities Commission's (THFC) decision to issue a certificate of need for a new healthcare facility. This ruling affects local governments and state agencies involved in healthcare facility approvals.

The case, Putnam County, Tennessee v. Tennessee Health Facilities Commission, was filed under docket number M2025-01961-COA-R10-CV. It centers on whether the county could contest the THFC's decision in its local court rather than being required to file in Davidson County, where the THFC is based.

Background

Putnam County opposed Cedar Recovery of Middle Tennessee, LLC's application to establish an opiate addiction treatment center in the county. Cedar Recovery filed its application in June 2024, and despite the county's objections at a THFC meeting in August 2024, the commission voted to approve the certificate of need.

In October 2024, Putnam County filed a petition for a common law writ of certiorari against the THFC and Cedar Recovery in the Putnam County Chancery Court. The THFC responded by seeking to dismiss the case or transfer it to Davidson County, claiming that the Putnam County court lacked jurisdiction and that venue was improper.

The Ruling

The Court of Appeals, led by Judge Andy D. Bennett, affirmed the trial court's decision that jurisdiction and venue were appropriate in Putnam County. The court stated, "We conclude that the trial court was correct" in its determination. The ruling clarified that the THFC is an independent state agency and not part of a state department, which influenced the venue decision.

The court emphasized that the relevant statutes allowed for a common law writ of certiorari to be filed in the county where the petitioners reside or where the agency has its principal office. Since the THFC does not have a statutory requirement to be sued in Davidson County, the court found that Putnam County's case could proceed locally.

Impact

This ruling is significant for local governments and state agencies in Tennessee, as it establishes that local courts can have jurisdiction over certain administrative decisions made by independent state agencies. This case sets a precedent that could allow other counties to challenge state agency decisions in their local courts, potentially altering how healthcare facilities are approved across the state.

Furthermore, the decision underscores the importance of understanding the jurisdictional boundaries of state agencies. It clarifies that unless a specific statute dictates otherwise, local courts may have the authority to hear cases involving state agencies, particularly in matters affecting local communities.

What's Next

The THFC may seek to appeal this ruling to a higher court, but details on any potential appeal were not available in the court filing. There are no related cases pending that directly connect to this ruling at this time.