Kennestone Hospital, Inc. v. Emory University

Summary

The court held that a certificate of need authorizing a hospital to operate as a particular type of hospital confers private property rights because it permits an individual holder to use its property in a specified way. The court also held that a court must first construe an administrative rule using traditional interpretive tools and may consider deference to the agency only if genuine ambiguity remains. Because the Court of Appeals may not have applied that framework, the court vacated its judgment and remanded without deciding whether Windy Hill must obtain a new certificate of need or whether any vested rights were unconstitutionally impaired.