Methodist Hospitals of Dallas v. Texas Industrial Accident Board
Methodist Hospitals of Dallas and numerous other hospitals sued the Industrial Accident Board to prevent the enforcement of Rule 42.110, which regulates hospital fees for workers' compensation patients. The hospitals argued that the rule was invalid due to the Board's failure to substantially comply with the Texas Administrative Procedure and Texas Register Act (APTRA) requirements for public benefit-cost notes and reasoned justifications during its adoption. The trial court denied the hospitals' request for a temporary injunction. On appeal, the court found that the hospitals made a prima facie showing that the rule was not adopted in substantial compliance with APTRA, specifically regarding the restatement of factual bases and reasons for disagreeing with party submissions. Despite this, the appellate court affirmed the trial court's denial of the temporary injunction, stating that the trial court has discretion to balance equities and public interest, and the appellate record lacked sufficient details of the trial court's reasoning to demonstrate an abuse of discretion.