Yakima Valley Memorial Hospital v. Washington State Department of Health
Opinion
Opinion
McKEOWN, J.
This appeal involves a constitutional challenge under the Commerce Clause to Washington State Department of Health (“Department”) Certificate of Need (“Certificate”) regulations. In particular, the challenge targets regulations related to scheduled, or “elective,” percutaneous coronary interventions (“PCIs”), which are nonsurgical procedures used to treat coronary heart disease. Hospitals without on-site cardiac surgical facilities may perform elective PCIs only if they obtain a Certificate demonstrating sufficient need in the region to support an annual minimum volume. Yakima Valley Memorial Hospital (“Memorial”) claims the requirement that elective PCIs be performed only at hospitals that have a minimum annual volume of 300 procedures lacks a reasonable basis and that its putative benefits, including safety, are outweighed by the burdens it places on interstate commerce, thus violating the dormant Commerce Clause. We disagree. The impact on interstate commerce, if any, is highly attenuated, and does not outweigh the safety benefits of the regulations. We affirm the district court’s dismissal of Memorial’s claims at summary judgment.