Vantage Cancer Centers of Georgia, LLC v. Georgia Department of Community Health (three Cases)

Summary

The Supreme Court of Georgia vacated the Court of Appeals’ judgments concerning the Commissioner’s review of a hearing officer’s certificate-of-need decision. It held that “competent substantial evidence” means admissible, relevant evidence that a reasonable mind might accept as adequate, and that the Commissioner may not reweigh evidence, assess witness credibility, or substitute factual judgment based on expertise. The Court also held that the Commissioner must state with sufficient detail why a finding lacks competent substantial evidence so a reviewing court can determine whether the Commissioner improperly substituted his judgment. The Court of Appeals was directed to apply these standards in the first instance on remand.