Paul Kimball Hospital, Inc., a Not-For-Profit Corporation of the State of New Jersey, Plaintiff-Respondent, and…

Summary

The Supreme Court of New Jersey held that the amendment to the Health Care Facilities Planning Act, N.J.S.A. 26:2H-7.1, is a valid, constitutionally permissible classification and does not constitute special legislation nor violate the Equal Protection Clause. The Court reasoned that the grandfather clause is supported by a rational basis related to municipal appropriations and reliance on pre‑Act actions, and therefore satisfies both the New Jersey Constitution’s prohibition on special legislation and the federal equal‑protection requirement. The Appellate Division’s decision was reversed. Justice Pashman, dissenting, argued that the amendment is unconstitutional special legislation designed solely for Brick Township Hospital.