In March 1988, P and Doctors Hospital both filed certificate of need applications to construct acute care hospitals providing similar services within close proximity to each other in the city of Sarasota. Doctors Hospital proposed to construct a completely new replacement of its existing physical plant at a different location. P proposed to construct a satellite hospital by transferring beds from its main physical plant. D received both applications in the same reviewing cycle but it did not comparatively review the applications because it was of the opinion that Doctors' was reviewable as a capital expenditure and P's was reviewable as an additional healthcare facility. D issued notices of intent to approve Doctors' application and to deny P's. P petitioned for a formal administrative hearing in which it sought comparative review of the two applications pursuant to rules and statutes. Doctors moved to dismiss P's petition. After conducting a hearing, the hearing officer issued an order in which he recommended that the motion be granted. D adopted the hearing officer's recommended order in its final order dismissing P's challenge to Doctors' application for lack of standing. P appealed.

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