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Abortion (Turnock V. Ragsdale) (Illinois Case)
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Abortion (Turnock V. Ragsdale) (Illinois Case)
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These records pertain to the Bush Administration's policies on abortion.
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Lee S. Liberman General Subject Files
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Originally Processed With FOIA(s): FOIA Number: 2012-2218-F 2012-2218-F FOIA MARKER This is not a textual record. This is used as an administrative marker by the George Bush Presidential Library Staff. Record Group/Collection: George H.W. Bush Presidential Records Collection/Office of Origin: Counsels Office, White House Series: Liberman, Lee S., Files Subseries: General Subject Files OA/ID Number: 45272 Folder ID Number: 45272-002 Folder Title: Abortion (Turnock V. Ragsdale) (Illinois Case) Stack: Row: Section: Shelf: Position: 0 O O O O Illinais Case Document Originally Attached to Following Page No. 88-790 NOV 10 1968 : Jh, CLERK IN THE Supreme Court of the United States OCTOBER TERM, 1988 K BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illinois Department of Public Health, et al., Appellants, V. RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From The United States Court Of Appeals For The Seventh Circuit JURISDICTIONAL STATEMENT NEIL F. HARTIGAN Attorney General, State of Illinois ROBERT J. RUIZ Solicitor General, State of Illinois 100 West Randolph Street, 12th Floor Chicago, Illinois 60601 (312) 917-3000 Attorneys for Appellants MICHAEL J. HAYES* * KATHLEEN KREISEL FLAHAVEN ROGER P. FLAHAVEN GLADYS STEVENS Assistant Attorneys General 100 West Randolph Street, 13th Floor Chicago, Illinois 60601 (312) 917-3654 Of Counsel * Counsel of Record Printed by Authority of the State of Illinois (P.O. 34272-60-11-10-88) i QUESTIONS PRESENTED 1. Whether Illinois can constitutionally license and regu- late outpatient surgical facilities in which pregnancy termi- nations are performed to the same extent it licenses and regulates outpatient surgical facilities in which pregnan- cy terminations are not performed. 2. Whether a case or controversy existed with respect to the challenged statutes and regulations which were not being enforced by the State of Illinois prior to the filing of the complaint. 3. Whether statutes and regulations establishing stan- dards for the construction, maintenance and operation of outpatient surgical facilities are constitutional as applied to outpatient surgical facilities in which pregnancy termi- nations are performed. 4. Whether the federal courts can refuse to give effect to severability requirements, thereby invalidating stat- utory and regulatory provisions which are constitutional. ii iii PARTIES TO THE PROCEEDINGS TABLE OF CONTENTS PAGE The defendants in the district court were Bernard J. Turnock, M.D., M.P.H., Director of the Illinois Depart- QUESTIONS PRESENTED i ment of Public Health; Neil F. Hartigan, Attorney Gen- PARTIES TO THE PROCEEDINGS ii eral of Illinois; Gary L. Clayton, the Director of the Illinois Department of Registration and Education; and TABLE OF CONTENTS iii Richard M. Daley, State's Attorney of Cook County. Tur- TABLE OF AUTHORITIES vi nock, Hartigan and Clayton were the appellants in the court of appeals. Daley did not file a notice of appeal. OPINIONS BELOW 1 JURISDICTION 1 In addition, appellant Stephen F. Selcke, Director of the Illinois Department of Professional Regulation, is the suc- CONSTITUTIONAL, STATUTORY AND cessor in public office to Gary L. Clayton, Director of the REGULATORY PROVISIONS INVOLVED 2 Illinois Department of Professional Regulation. STATEMENT OF THE CASE 4 The plaintiffs in the district court and appellees in the court of appeals were Richard M. Ragsdale, M.D., Mar- The State Statutes 5 garet Moe, Northern Illinois Women's Center, Sarah Roe The Evidence Presented 6 and Jane Doe. Abortion Procedures 8 Enforcement Policies 9 The ASTC Regulations 11 Building Design and Construction Require- 13 ments The Constitutional Challenge 14 THE QUESTIONS PRESENTED ARE SUB- STANTIAL 21 A. THE COURT ERRONEOUSLY ASSUMED JURISDICTION OVER CERTAIN CHAL- LENGED PROVISIONS WHICH WERE NOT BEING ENFORCED 21 V iv F- Class Certification and Preliminary Injunction B. THE MAJORITY OPINION ERRONEOUS- Order of the United States District Court for LY FOUND THAT THE CHALLENGED STATUTES AND REGULATIONS VIO- the Northern District of Illinois, Eastern Divi- LATE THE CONSTITUTIONAL RIGHT TO sion, December 11, 1985 109 PRIVACY 24 G-Memorandum Opinion and Order of the United C. THE MAJORITY OPINION CONFLICTS States District Court for the Northern District WITH DECISIONS OF THIS COURT RE- of Illinois, Eastern Division, November 27, GARDING SEVERANCE OF PURPORTED 1985 112 LY UNCONSTITUTIONAL PROVISIONS 28 H-Notice of Appeal, November 7, 1988 146 CONCLUSION 30 I- Ambulatory Surgical Treatment Center Act, 111½ III. Rev. Stat. 11 157-8.1, et seq. 149 APPENDIX J- Health Facilities Planning Act, 111½ III. Rev. (Separate Volume) Stat. 11 1151, et seq. 166 APP. K-Medical Practice Act, 111 III. Rev. Stat. 1 4400- PAGE 22 193 A-Slip Opinion of the United States Court of L-77 Illinois Administrative Code, Chapter 1, Appeals for the Seventh Circuit, March 10, § 205, Subchapter b 203 1988 1 B-Judgment of the United States Court of Ap- peals for the Seventh Circuit, March 10, 1988 102 C-Order of the United States Court of Appeals for the Seventh Circuit Amending the Slip Opinion, April 13, 1988 103 D-Amended Order of the United States Court of Appeals for the Seventh Circuit Denying the Petition for Rehearing and Suggestion for Re- hearing En Banc, August 16, 1988 105 E-Order of the United States Court of Appeals for the Seventh Circuit Denying the Petition for Rehearing and Suggestion for Rehearing En Bano, August 12, 1988 107 vi vii TABLE OF AUTHORITIES Minneapolis Star & Tribune Co. v. Minn. Comm'n of Revenue, 460 U.S. 575 (1983) 26 Planned Parenthood Ass'n v. Ashcroft, 462 U.S. Cases PAGE(S) 476 (1983) 10, 27 Abortion Coalition of Mich., Inc. v. Mich. Dep't Poe v. Ullman, 367 U.S. 497 (1961) 23 of Public Health, 426 F.Supp. 471 (E.D. Mich. Regan v. Time, Inc., 468 U.S. 641 (1984) 29 1977) 26 Roe v. Wade, 410 U.S. 113 (1973) 15, 18, 19, 24 Arcara v. Cloud Books, Inc., 478 U.S. 697 (1986) 26 Simopoulos v. Virginia, 462 U.S. 506 (1983) 10 Baird v. Department of Public Health, 599 F.2d 1098 (1st Cir. 1979) 25 Thornburgh v. American College of Obstetricians, 476 U.S. 747 (1986) 19 Buckley v. Valeo, 424 U.S. 1 (1976) 29 Village of Oak Lawn v. Marcowitz, 86 Ill.2d 406 Champlin Refining Co. v. Corporation Commis- (1981) 9, 10, 28 sion, 286 U.S. 210 (1932) 29 Watkins v. Blinzinger, 789 F.2d 474 (7th Cir. 1986) 23 Charles v. Carey, 579 F.Supp. 464 (N.D. III. 1983) 10 Westchester Women's Health Org. v. Whalen, 475 C.I.O. v. McAdory, 325 U.S. 472 (1945) 23 F.Supp. 734 (S.D.N.Y. 1979) 25, 26 City of Akron v. Akron Center for Reproductive Health, Inc., 462 U.S. 416 (1983) 10, 15, 24 Constitutional Provisions City of Renton v. Playtime Theatres, Inc., 475 U.S. U.S. Const. Amend. I 2, 5 41 (1986) 26 U.S. Const. Amend. IV 3,5 Connecticut v. Menillo, 423 U.S. 9 (1975) 24 U.S. Const. Amend. V 3, 5 El Paso & Northeastern R. Co. v. Gutierrez, 215 U.S. 87 (1909) U.S. Const. Amend. IX 3, 5 29 Green v. Mansour, 474 U.S. 64 (1985) 23 U.S. Const. Amend. XI 3, 23 Hodgson v. Lawson, 542 F.2d 1350 (8th Cir. 1976) 25 U.S. Const. Amend. XIV, Section 1 3, 4, 5 International Harvester Co. v. Deere & Co., 623 F.2d 1207 (7th Cir. 1980) 23 J.N.S., Inc. v. State of Ind., 712 F.2d 303 (7th Cir. 1983) 23 viii Statutes 28 U.S.C. Section 1343 1 28 U.S.C. Section 2201 1 28 U.S.C. Section 2202 1 IN THE 42 U.S.C. Section 1983 1 Ambulatory Surgical Treatment Center Act, Supreme Court of the United States III. Rev. Stat. ch. 111½, pars. 157-8.1 et seq. : OCTOBER TERM, 1988 passim Health Facilities Planning Act, III. Rev. Stat. ch. 111½, pars. 1151 et seq. passim BERNARD J. TURNOCK, M.D., M.P.H., Director of Medical Practice Act, the Illinois Department of Public Health, et al., III. Rev. Stat. ch. 111, par. 4400-22 passim Appellants, ...... V. Regulations RICHARD M. RAGSDALE, M.D., et al., Ambulatory Surgical Treatment Center Licensing Appellees. Requirements, 77 III. Adm. Code, Ch. 1, Sec- tion 205, Subchapter 6 passim On Appeal From The United States Court Of Appeals For The Seventh Circuit JURISDICTIONAL STATEMENT -1- OPINIONS BELOW The opinion of the United States Court of Appeals for the Seventh Circuit entered March 10, 1988 is reported at 841 F.2d 1358 (7th Cir. 1988) and is reproduced at Ap- pendix A. On August 12, 1988 the defendants' petition for rehearing and suggestion for rehearing en banc was denied. (Appendix D, E). The memorandum opinion of the United States District Court for the Northern District of Illinois rendered November 27, 1985 is reported at 625 F.Supp. 1212 (N.D. III. 1985) and is reproduced at Ap- pendix G. The judgment order of the United States District Court entered December 11, 1985 is not reported, but is repro- duced at Appendix F. JURISDICTION This action, brought under 28 U.S.C. Sections 2201 and 2202 and 42 U.S.C. Section 1983 challenges the constitu- tionality of portions of the Illinois Medical Practice Act, Ambulatory Surgical Treatment Center Act, and Health Facilities Planning Act. Invoking the jurisdiction of the District Court under 28 U.S.C. Section 1343 plaintiffs filed a class action seeking declaratory and injunctive relief. Subsequent to an evidentiary hearing, the District Court entered on November 27, 1985 and December 11, 1985 a preliminary injunction in favor of plaintiffs and enjoined enforcement of the Acts and rules promulgated thereunder to the extent any person or facility offers or performs, or desires to offer or perform first and/or early second -2- -3- trimester abortions or other abortion-related gynecological U.S. Const. Amend. IV: procedures. The right of the people to secure in their persons, On appeal, the United States Court of Appeals for the houses, papers, and effects, against unreasonable Seventh Circuit vacated as moot one portion of the Dis- searches and seizures, shall not be violated, and no trict Court's decision, held unconstitutional the other chal- Warrants shall issue, but upon probable cause, sup- lenged provisions, and affirmed the remainder of the deci- ported by Oath or affirmation, and particularly de- scribing the place to be searched, and the person or sion. Its judgment was entered on March 10, 1988. things to be seized. On August 12, 1988 a majority of the members of the U.S. Const. Amend. V: original panel voted to deny the defendants' petition for No person shall be held to answer for a capital, or rehearing, and the suggestion for rehearing en banc failed otherwise infamous crime, unless on a presentment by an equally divided court. Judges Wood, Posner, Coffey, or indictment of a Grand Jury, except in cases aris- Manion, and Kanne voted to grant rehearing en banc. (Ap- ing in the land or naval forces, or in the Militia, when pendix D, E). in actual service in time of War or public danger; nor shall any person be subject for the same offence to Defendants Turnock, Hartigan and Selcke filed their be twice put in jeopardy of life or limb; nor shall be Notice of Appeal in the Court of Appeals on November compelled in any criminal case to be a witness against 7, 1988. (Appendix H). Jurisdiction of the Supreme Court himself, nor be deprived of life, liberty, or property, of the United States to review this judgment by appeal without due process of law; nor shall private property is conferred by 28 U.S.C. Section 1254(2). be taken for public use, without just compensation. U.S. Const. Amend. IX: The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage CONSTITUTIONAL, STATUTORY AND others retained by the people. REGULATORY PROVISIONS INVOLVED U.S. Const. Amend. XI: The Judicial power of the United States shall not be construed to extend to any suit in law or equity, com- Constitutional Provisions menced or prosecuted against one of the United U.S. Const. Amend. I: States by Citizens of another State, or by Citizens Congress shall make no law respecting an establish- or Subjects of any Foreign State. ment of religion, or prohibiting the free exercise U.S. Const. Amend. XIV, Section 1: thereof; or abridging the freedom of speech, or of the All persons born or naturalized in the United States, press; or the right of the people peaceably to assem- and subject to the jurisdiction thereof, are citizens ble, and to petition the Government for a redress of of the United States and of the State wherein they grievances. reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any -4- -5- person of life, liberty, or property, without due process the performance of first and second trimester abortions. of law; nor deny to any person within its jurisdic- Specifically, plaintiffs alleged that the challenged statutes tion the equal protection of the laws. and regulations were violative of rights secured by the First, Fourth, Fifth, Ninth and Fourteenth Amendments State Statutes to the United States Constitution. Plaintiffs contended Ambulatory Surgical Treatment Center Act, that the "scheme" as applied singles out for discrimina- III. Rev. Stat. ch. 111½, pars. 157-8.1 et seq. tory treatment facilities in which abortions are performed (Reprinted at Appendix I) and substantially inhibits a woman from exercising her Health Facilities Planning Act, right to choose to have an abortion under medically safe III. Rev. Stat. ch. 111½, pars. 1151 et seq. and reasonably inexpensive conditions. Plaintiffs further (Reprinted at Appendix J) averred that the challenged "scheme" impermissibly pre- Medical Practice Act, vented physicians from implementing a woman's decision III. Rev. Stat. ch. 111, par. 4400-22 to choose abortion in that the "scheme" mandated that (Reprinted at Appendix K) physicians and facilities comply with allegedly irrational and arbitrary requirements. (Compl., pars. 1-4). Regulations Ambulatory Surgical Treatment Center On September 20, 1985 plaintiff Richard M. Ragsdale, Licensing Requirements, 77 III. Adm. Code, Ch. 1, M.D. filed a motion for preliminary injunction asking the Section 205, Subchapter b district court to enjoin defendants from enforcing the chal- (Reprinted at Appendix L) lenged statutes and regulations. Plaintiff Ragsdale claimed that unless the statutes and regulations were enjoined he would be unable to perform abortion services after De- STATEMENT OF THE CASE cember 31, 1985. The State Statutes Plaintiff Ragsdale is a medical doctor licensed in Illinois, The Ambulatory Surgical Treatment Center Act [herein- who performs abortions as part of his medical practice. after ASTC Act] became law in 1973. (Appendix I). The Plaintiff Northern Illinois Women's Center is an Illinois stated purpose of the ASTC Act is to provide for the pro- corporation which provides abortion services to women tection of the public health through the establishment and in Rockford, Illinois. Plaintiff Margaret Moe is a regis- enforcement of standards for the construction and opera- tered nurse and the sole owner of a medical facility in tion of ASTCs. ASTCs by definition are facilities which Cook County, Illinois. Plaintiffs Sarah Roe and Jane Doe are primarily devoted to the performance of surgical pro- are female citizens of child-bearing age who had abortions cedures.¹ in the past and may seek abortions in the future. 1 In addition to ASTCs, the Illinois Department of Public Health Plaintiffs claimed that the challenged statutes form a is responsible for licensing and surveying numerous other facilities tripartite regulatory scheme which impermissibly restricts (Footnote continued on following page) -6- -7- The Illinois Health Facilities Planning Act [HFP Act] ASTCs, 22 indicated that some pregnancy terminations became law in 1974. (Appendix J). The purpose of the HFP Act is to attempt to obtain a comprehensive health would be performed. care delivery system involving all types of health care For the 12 years prior to trial Dr. Ragsdale was the facilities, services and equipment. The HFP Act also rep- primary abortion provider in northwestern Illinois. Dr. resents an attempt to restrain the rising costs of health Ragsdale is well known as a provider of abortion services care by preventing unnecessary construction and duplica- in the Rockford area. In 1973 Dr. Ragsdale opened the tion of unneeded health care facilities. (App. 166). Types plaintiff Northern Illinois Women's Center. The Center of health care facilities included within the HFP Act's pro- primarily provides first and early second trimester abor- visions include those licensed pursuant to the Health Main- tion services. Dr. Ragsdale performs approximately 3500 tenance Organization Act, the ASTC Act, the Nursing abortions per year at his facility. In the 12 years prior Home Care Reform Act of 1979, the Hospital Licensing to trial, Dr. Ragsdale had performed in excess of 42,000 Act, and kidney disease treatment centers. (App. 167). abortions. The Medical Practice Act [MPA] provides the licensure At the time of trial, Dr. Ragsdale's facility had been requirements of physicians in Illinois and prohibits the licensed as an ASTC in Illinois for 12 years. The facility practice of medicine by any person not holding a valid contained variations from the ASTC regulations. Any such license. III. Rev. Stat. ch. 111, par. 4401 et seq. (1983). variances had not substantially affected renewal of Dr. Now, par. 4400-1 et seq. of the Medical Practice Act of Ragsdale's license for those 12 years. Dr. Ragsdale was 1987. (Appendix K). then informed by his landlord that his lease would not be renewed. The nonrenewal of the lease was a result The Evidence Presented of the landlord's decision to expand and renovate its build- ing and desire to have as tenants doctors who admitted At the time of trial, there were 42 licensed ASTCs in patients to Rockford Memorial Hospital. Dr. Ragsdale Illinois. The types of surgical procedures performed in li- therefore planned to move his facility. The Illinois Depart- censed ASTCs include plastic surgery, removal of cysts ment of Public Health preliminarily approved his plans and tumors, pregnancy terminations, tubal ligations, hernia for relocation. In addition, Dr. Ragsdale submitted an ap- repairs and rhinoplasty repairs of the nose. Some surgical plication for a certificate of need. procedures performed in ASTCs, including abortions, are done 80 under a general anesthesia. Of the 42 licensed On March 14, 1985 Comprehensive Health Planning of Northern Illinois (CHPNI) held a public meeting regard- ing the proposed relocation. CHPNI is a federally funded 1 continued organization which is a separate entity from the HFP which provide health or medical services. These facilities include Board. It is responsible for completing an independent re- blood banks, clinical laboratories, alcohol treatment centers, hos- view of a proposed project. pitals, hospices, and nursing homes. III. Rev. Stat. ch. 111½, pars. 601-101 et seq.; 621-101 et seq.; 2301 et seq.; 142 et seq.; 6101 et Dr. Ragsdale attended the CHPNI meeting. There were seq.; and 4151-101 et seq. in Dr. Ragsdale's opinion some "rational" discussions at -8- -9- the meeting, and some statements supporting the need Abortions, more than any other types of procedures, re- issue. There were, in addition, more statements that there quire much experience and practice. It is not a procedure was no need for the facility. The meeting then degener- which can be done well after a few hundred or even a ated into a shouting match over abortion. few thousand procedures. Dr. Ragsdale was subsequently informed by CHPNI There are several factors which affect the safety of first that his proposal met the review requirements, including trimester and early second trimester abortion procedures. the need requirement. However, the lease which Dr. Rags- One factor is the skill, experience and professional integri- dale had procured was withdrawn by the lessor. ty of the physician performing the abortion. Other factors include the duration of the pregnancy; choice of abortion In order to aid his testimony at trial, Dr. Ragsdale de- technique; the existence of sterile conditions; the availabil- termined what it would cost on a rough basis and in broad ity of qualified staff and appropriate equipment; the avail- terms to comply with the ASTC Act and regulations at ability of emergency facilities; and the type of anesthesia his new facility. Dr. Ragsdale first estimated the cost of which is used. relocation of his practice as a result of the loss of his lease, and without complying with the ASTC Act and Enforcement Policies regulations. Dr. Ragsdale concluded that the cost would be an additional $22.45 per patient per year. In 1981, the Supreme Court of Illinois rendered its deci- sion in Village of Oak Lawn v. Marcowitz, 86 Ill.2d 406 Dr. Ragsdale also prepared an estimate which repre- (1981). In Marcowitz the court considered a village ordi- sented his guess as to what it would cost in addition to nance which had adopted the definition of an ASTC that the $22.45 in order to bring his new facility into "reason- was found in the State ASTC Act. The Supreme Court able compliance" with the ASTC regulations. Dr. Ragsdale of Illinois held that the ordinance was unconstitutional to estimated that the cost would be an additional $22.21 per the extent that it defined an ASTC to be any facility in patient per year. which abortions are performed, irrespective of whether devoted primarily to that purpose. Marcowitz, 86 III.2d Abortion Procedures at 420. The court then severed that portion of the defini- It is uncontroverted that abortions are surgical pro- tion of an ASTC from the remainder of the ordinance. cedures. According to the plaintiffs' expert witnesses, Four days after Marcowitz was decided, the Illinois De- there are few surgical procedures given so little atten- partment of Public Health, pursuant to a written policy, tion and so underrated in its potential hazard as abor- ceased to enforce the identical abortion specific portion tion. It is also agreed that all physicians licensed under of the definition of an ASTC found in the State statute. the MPA do not have the qualifications, training and ex- Since 1981, therefore, licensure and enforcement proceed- perience to perform safe first and early second trimester ings were applicable only to those facilities primarily de- abortions. voted to the performance of surgical procedures. Plaintiffs' expert maintained that medical education in this country has paid little attention to abortion services. -10- -11- In 1982, United States District Judge Charles P. Kocoras 193) was not being enforced by the Department to restrict enjoined the Illinois Department of Public Health from the performance of all abortions to licensed facilities. enforcing Section 4 of the Illinois Abortion Law of 1975 and "any related regulation." Section 4 was a second tri- The evidence submitted regarding the State's enforce- mester hospitalization requirement. The Department inter- ment policies in light of various decisions was not contro- preted this ruling as also enjoining the enforcement of verted. ASTC Regulation Section 205.740 which prohibited the performance of second trimester abortions in ASTCs. The ASTC Regulations (App. 222). There are a total of 59 ASTC Regulations (excluding In 1983, this Court decided the cases of City of Akron subsections). Of that total very few are abortion specific. v. Akron Center For Reproductive Health, Inc., 462 U.S. Of the abortion specific regulations, as previously noted, 416 (1983); Planned Parenthood Ass'n v. Ashcroft, 462 two were not being enforced prior to the filing of plain- U.S. 476 (1983); and Simopoulos v. Virginia, 462 U.S. 506 tiffs' complaint. (1983). The decision in Akron reinforced the earlier or- Plaintiffs' experts testified generally that the ASTC der, and the Department's policy of not enforcing Section regulations were not medically necessary for the perform- 205.740 of the Regulations therefore continued. ance of a safe first or early second trimester abortion. In December of 1982 or January of 1983 Dr. Ragsdale Certain components of the regulations, however, were ac- was informed that Section 205.740 of the ASTC Regula- knowledged to be consistent with safe and acceptable stan- tions was no longer being enforced. As a result, Dr. Rags- dards of medical care. Moreover, some regulations were dale began to perform second trimester abortions at his described as belaboring the obvious, the kind of thing any facility. competent practitioner would do, and superfluous. In 1983, in Charles v. Carey, 579 F.Supp. 464 (N.D. III. For example, Section 205.240 of the regulations provides 1983), Section 10 of the Illinois Abortion Law of 1975 (the that the ASTC is to formulate a written policies and pro- reporting requirement) was permanently enjoined. As a cedures manual. (App. 213). Dr. Ragsdale described this result Section 205.760 (App. 223), an abortion specific requirement as standard medical and administrative prac- reporting requirement of the ASTC Regulations was no tice. longer enforced. Dr. Ragsdale was informed that this sec- Likewise, Section 205.230(a) of the regulations provides tion was no longer being enforced. that the management of a licensed ASTC is to appoint The Illinois Department of Registration and Education a qualified consulting committee. (App. 211). Dr. Ragsdale (now Department of Professional Regulation) has absolute testified that this regulation is "belaboring the obvious." prosecutorial discretion in the initiation of disciplinary Similarly, the plaintiffs' expert testified that either the actions under the Medical Practice Act. Because of the medical director or principal physician of an abortion facil- Marcowitz decision and other decisions concerning the ity should have staff privileges at the nearest hospital, abortion issue, the challenged portion of the MPA (App. or there should be a hospital transfer agreement. Section -12- -13- 205.540(c) of the regulations provides that there should certain surgical procedures. (App. 216-17). Section 205.730(a) be written documentation of either a transfer agreement, provides that prior to obstetrical procedures blood Rh fac- a statement that the medical director has admitting privi- tor is to be determined and that prior to performing an leges, or that each staff physician, podiatrist or dentist abortion procedure the diagnosis of pregnancy is to be has admitting privileges. (App. 218). established. (App. 221). Subpart G of the regulations sets forth additional require- It is similarly agreed that after every abortion, removed ments for facilities in which obstetrical/gynecological pro- tissue should be examined. One of the purposes of the cedures are performed. (App. 220-23). This section applies pathology report is to confirm pregnancies in early stages. to abortions as well as other gynecological and obstetric Another purpose is to ensure that fetal parts are present procedures. Plaintiffs' expert testified that there are and to be able to alert patients to the possibility of an aspects of Subpart G which are consistent with good stan- ectopic pregnancy. Section 205.530(c) of the ASTC regula- dards of medical practice. tions merely provides that all tissues removed during The American College of Obstetricians and Gynecologists' surgery are to be examined by a consulting pathologist. Standards for Obstetrie-Gynecologic Services, Sixth Edi- (App. 217). tion [ACOG standards], provide that ambulatory care facil- ities for abortion services should meet the same standards Building Design and Construction Requirements of care as for other surgical procedures. Section 205.710 Subparts (I) and (J) of the ASTC regulations set forth of the ASTC regulations contains an essentially identical various building design, construction standards, and physi- provision. (App. 220). The parties' expert witnesses agreed cal and mechanical requirements. (App. 225-44). Plaintiffs' with this provision. expert, who did not consider himself a building design, Likewise, plaintiffs' expert testified that counseling is construction, or mechanical expert testified that the pro- an indispensable part of a thorough preoperative evalua- visions of Subparts (I) and (J) are not medically necessary tion and preparation of a patient for an abortion pro- for the operation of a facility in which first and early sec- cedure, and that counseling should include a discussion ond trimester abortions are to be performed. The defen- of the alternatives for dealing with pregnancy. Section dants introduced evidence demonstrating that many of 205.730(b) of the regulations provides that counseling is to these regulations reflect common, accepted and standard be provided prior to obstetrical/gynecological procedures practices. following diagnosis of pregnancy. (App. 221). For example, Section 205.1510 of the regulations pro- It is agreed that routine laboratory work for abortion vides that after building heating, ventilating and air condi- procedures should include a urine screening exam for preg- tioning systems are installed they shall be tested and nancy, a hematocrit or hemoglobin, an Rh screening test, balanced to ensure that they are in proper working con- dip stick urinalysis and for black patients a sickle cell test. dition. (App. 240). The regulation also provides that upon Section 205.520(b) of the regulations simply provides that completion of the facility, the owner of the ASTC is to a hemoglobin or hematocrit is to be performed prior to be provided with operating and maintenance instructions. -14- -15- Section 205.1520 provides, among other things, for insula- Next, the district court determined that the threatened tion in the facility and in certain situations for a flame harm to plaintiffs outweighed any possible harm to defen- spread rating in accordance with the National Fire Pro- dants. (App. 134). tection Association. (App. 240-41). These requirements Third, the district court considered the merits of plain- were described as standard for health facilities. tiffs' claims. It utilized the trimester standard established Similarly, various regulations dealing with hot water in Roe v. Wade, 410 U.S. 113 (1973), as interpreted in City systems, ventilation systems, and plumbing fixtures were of Akron v. Akron Center for Reproductive Health, 426 demonstrated to be standard requirements. U.S. 416 (1983) and other cases, to provide the legal frame- work for the constitutional evaluation of the challenged statutes and regulations. (App. 134-35). The Constitutional Challenge The district court noted that State regulations having The trial conducted by the district court was held on no significant impact on a woman's exercise of her abor- November 18-22 and 26, 1985. On November 27, 1985 and tion right during the first trimester may be permissible December 11, 1985 the district court entered orders grant- where justified by important State health objectives. It ing Dr. Ragsdale's motion for preliminary injunction. held, however, that Roe does not stand for the proposi- In the November 27, 1985 Order, the district court found tion that general medical regulations which apply to the that plaintiffs had prevailed on all four traditional factors performance of first and early second trimester abortions the courts must consider in ruling on a motion for prelim- are per se constitutional. (App. 136). Thus, the district inary injunction. (App. 129). First, the district court de- court concluded that even general regulations which bur- cided that plaintiffs would suffer irreparable harm with- den a woman's right to choose to terminate her pregnancy out an injunction and that no adequate remedy at law during the first trimester would have to meet the com- existed. Specifically, it found that the challenged statutes pelling governmental interest requirement. In addition, the and regulations have the effect of raising the cost and district court decided that a regulation which burdens a limiting the availability of abortions. (App. 129). In addi- woman's right to choose to terminate her pregnancy dur- tion, the district court found that the challenged provi- ing the early second trimester must be reasonably related sions (1) force complying facilities to raise their fees, to the preservation and protection of maternal health. possibly beyond the economic means of some women; (2) (App. 137). discourage other non-complying facilities from offering Applying these standards to this case, the district court abortion services; and (3) make it difficult, if not impossi- found that plaintiffs had demonstrated that the statutory ble, for current abortion facilities to move or new abor- and regulatory scheme places a burden on a woman's tion facilities to be constructed. (App. 130). Further, the right to choose to terminate her pregnancy during the district court rejected defendants' argument that plain- first and early second trimester. Specifically, it found that tiffs could not be irreparably harmed by those statutes the challenged provisions (1) increase the cost and de- and regulations which are not being enforced. (App. 133). crease the availability of abortions and (2) may delay the effectuation of a woman's decision to abort. (App. 137). -16- -17- Further, the district court found that defendants had In addition, the district court specified that in deciding failed to produce any evidence of a compelling or even whether a health care facility was devoted primarily to rational basis for the challenged statutes and regulations. the performance of surgical procedures, and therefore re- It noted that defendants had shown that certain regula- quired to be licensed under the ASTC Act, the Illinois tions are consistent with accepted medical practice, but Department of Public Health is not prohibited from count- that such showing is not equivalent to a demonstration ing the number of abortion procedures performed in the that the challenged provisions are medically necessary. facility. The Department cannot, however, enforce the Thus, the district court found a reasonable likelihood that regulations as to the abortion procedures performed-but plaintiffs will succeed on the merits. (App. 137-38). can enforce the regulations as to other procedures per- Lastly, the district court determined that the public in- formed at the facility. terest would be served by the issuance of the preliminary Defendants appealed from the district court's orders to injunction. (App. 139). the United States Court of Appeals for the Seventh Cir- The defendants were preliminarily enjoined and restrained cuit. On March 10, 1988 that court rendered its decision from enforcing the challenged provision of the Medical in this matter. (App. 1). The majority opinion affirmed, Practice Act (MPA); the Ambulatory Surgical Treatment with one exception, the district court's entry of a pre- Center Act (ASTC) and the rules and regulations promul- liminary injunction. The exception is the challenge to one gated thereunder; and the Health Facilities Planning Act ASTC regulation-a second trimester hospitalization re- (HFP): to the extent any person or facility offers or per- quirement-which the majority held was not being en- forms, or desires to offer or perform first and/or early forced, was moot, and should have been dismissed. Judge second trimester abortions or other abortion-related gyne- Coffey submitted a lengthy dissent from the majority cological procedures. (App. 110-11). opinion. (App. 34-80). The district court also certified the following classes: The majority opinion first considered whether certain (a) a plaintiff class of physicians and surgeons who per- of plaintiffs' challenges have been mooted by the State's form or desire to perform abortions in Illinois; (b) a plain- policy of nonenforcement. It noted that the voluntary ces- tiff class of all Illinois women of child-bearing age who sation of putatively illegal conduct ordinarily will not moot desire or may desire an abortion sometime in the future; a controversy and prevent its adjudication by a federal and (c) a defendant class of all State's Attorneys in Illi- court. (App. 10-11). Further, the majority stated that such cessation does render a controversy moot when there is nois. (App. 110). no reasonable expectation that the putatively illegal con- On December 11, 1985 the district court orally clarified duct will be repeated and that there are no remaining portions of its ruling. The district court specified that the effects of the alleged violation. (App. 11). Illinois Department of Public Health is not enjoined from Applying these principles to this case, the majority regulating ASTCs in which abortions are performed or desired to be performed to the extent that such ASTCs found the challenge to the second trimester hospitaliza- are performing surgical procedures other than abortions. tion requirement is moot because enforcement ceased in -18- -19- 1983. (App. 11-13). It held, however, that the challenge voted to surgery, those regulations should be reviewed to the reporting requirement of the ASTC Act and regula- under a different standard than if they had singled out tions is not moot because the State did not produce pre- abortions. (App. 21). In addition, it decided that the dis- existing documentation of the nonenforcement policy. trict court's findings that the challenged provisions sub- (App. 13). Finally, it held that the challenge to the appli- stantially burden the effectuation of the abortion decision cation of the ASTC Act and regulations to first trimester were not clearly erroneous. (App. 22). abortions is not moot. It noted that those requirements The first facet of the challenged statutes and regula- were no longer applied to the occasional abortion provider, tions which the majority considered was the requirement but that such requirements were applied to doctors who that facilities performing abortions be licensed. (App. 23). exclusively perform first trimester abortions. Further, the It held that under Roe the State may not require separate majority stated that the evidence on this point-testimony licensure of facilities primarily devoted to performing abor- from the legal counsel for the state agency charged with tions during the first trimester. (App. 24). Once the licens- enforcement authority that the challenged provision of the ing requirement falls, the majority reasoned that the re- MPA was not being enforced-was too ambiguous. (App. maining requirements fall with it. (App. 25). 13-14). Nevertheless, the majority considered and ruled upon In considering the merits of the case, the majority opin- the constitutionality of three abortion-specific regulations. ion, like the district court, relied upon the "trimester" First, it construed section 205.730(a)(2) (App. 221) to un- approach of Roe v. Wade, 410 U.S. 113 (1973). (App. 15). constitutionally require the physician who is to perform It analyzed various decisions of this Court and stated that the abortion to also perform a pregnancy test, even if where first trimester abortions are involved, not only such test had previously been done by another physi- must the impact of the challenged regulations be insignifi- cian. (App. 27). Second, the majority held that section cant in terms of the woman's exercise of her right, but 205.730(b)(3) (App. 221-22) invalidly requires counseling to also the regulation must be justified by important state include a discussion of alternatives, citing Thornburgh v. health objectives. (App. 17). American College of Obstetricians, 476 U.S. 747 (1986). The majority found that statement consistent with exist- (App. 27). Third, it construed section 205.730(b)(2)(D) (App. ing Seventh Circuit precedent which holds that once such 221) to unconstitutonally preclude the performing physi- regulations are shown to have more than a de minimus cian from providing the counseling. (App. 28-29). impact on the abortion decision, the government must The generally applicable regulations regarding physical show a compelling basis for the law, i.e., that the burden plant, equipment, and staffing were also struck down by is not undue or unjustifiable. (App. 17). Thus, the major- the majority. It concluded that those provisions impose ity opinion concluded that the district court's application a substantial burden and are not justified by health ob- of a "medical necessity" standard was consonant with the jectives. (App. 29-31). legal framework applicable to this case. (App. 18). Fur- In addition, the majority found the "certificate of need" ther, the majority rejected defendants' argument that be- proceeding of the Health Facilities Planning Act unconsti- cause the regulations apply to all facilities primarily de- -20- -21- tutional. It held the State's interest in preventing wasteful THE QUESTIONS PRESENTED duplication of resources to be insufficient in this context. ARE SUBSTANTIAL (App. 31-32). Finally, the majority rejected defendants' request to sever those provisions which were held unconstitutional. This appeal is of exceptional importance because the ma- It reasoned that severance was not appropriate because jority opinion, under the guise of protecting a woman's the licensure provision had been invalidated. (App. 32). constitutional right to privacy, has exempted outpatient Further, it found that the challenged provisions were "so surgical facilities in which abortions are performed from riddled with exceptions resulting from judicial decisions general licensure and regulatory provisions. In SO doing, and nonenforcement policies as to be unintelligible." Un- the majority emasculates the duty and authority of the der those circumstances, the majority found that it could State of Illinois to protect the health, safety, and welfare not untangle the constitutional from the unconstitutional of its citizens by licensing and regulating outpatient surgi- provisions. (App. 32-33). cal facilities in which first or early second trimester abor- The dissenting opinion finds that the States are author- tions are performed in the same manner that other surgi- ized under Roe to apply the same licensing standards to cal facilities are regulated. abortion facilities as those applied to facilities perform- Further, the majority opinion is in conflict with deci- ing similar surgical procedures. (App. 35). Under that stan- sions of this Court with respect to the jurisdictional issues dard, the dissent would enjoin and sever the challenged presented in this case. The opinion is also in conflict with portion of the Medical Practice Act and the abortion spe- decisions of this Court and other courts of appeals with cific language of par. 157-8.3(A) of the ASTC Act. (App. respect to the authority of the State to license and regu- 38). It argues that the States are free to regulate ambu- late outpatient surgical facilities in which abortions are latory surgical treatment centers, including those perform- performed. Finally, the refusal of the majority opinion to ing abortions, as long as the abortions are not singled out sever any purportedly unconstitutional provisions is in con- from other, similar surgical procedures, subject to the ra- fliet with decisions of this Court. tional basis test governing social and economic legislation. Under the rational basis test, moreover, the dissent finds A. the ASTC Act and IHFP Act constitutional. (App. 64). THE COURT ERRONEOUSLY ASSUMED JURISDIC- In evaluating the abortion-specific statutes and regulations TION OVER CERTAIN CHALLENGED PROVISIONS under the strict scrutiny test, the dissent would uphold WHICH WERE NOT BEING ENFORCED. all provisions but one [section 205.730(b)(2)(D)]. (App. 73). At trial, the defendants introduced evidence that due The dissent finds that the challenged provisions neither to various court decisions which pre-date the complaint burden the abortion decision or its effectuation and are in this matter, certain challenged provisions were not be- justified by important health objectives. (App. 80). ing enforced by the State. Those provisions are: the abor- tion specific language of par. 157-8.3 of the ASTC Act (App. 149-50); Section 205.740 (App. 222) (prohibition of -22- -23- second trimester abortions in ASTCs) and 205.760 (App. whether a justiciable controversy exists. International 223) (abortion specific reporting requirement) of the ASTC Harvester Co. v. Deere & Co., 623 F.2d 1207, 1210 (7th Regulations; and par. 4400-22 of the MPA. (App. 193). This Cir. 1980). Even where fundamental rights are allegedly evidence was not contradicted. involved, "a litigant must establish a more immediate threat than simply a general policy of enforcing laws." Nonetheless, the majority held with respect to the re- J.N.S., Inc. v. State of Ind., 712 F.2d 303, 305 (7th Cir. porting requirement of Section 205.760 that the State's 1983) (lack of justiciable controversy found in challenge position of nonenforcement is "asserted only in this litiga- by seller of sexually explicit materials to state civil RICO tion." This conclusion is clearly erroneous. The evidence statutes). Thus, the courts should not pass on the constitu- reveals that this provision has not been enforced since tionality of challenged provisions which are not being en- 1983. With respect to the challenged provision of the forced. Poe v. Ullman, 367 U.S. 497, 507 (1961) (lack of MPA, the majority held that the evidence of nonenforce- justiciable controversy found in challenge to prohibition ment is "equivocal." This conclusion is also erroneous. against provision of contraceptive advice and use of Legal counsel to the Department of Registration and Edu- contraceptive devices); C.I.O. v. McAdory, 325 U.S. 472, cation (now Department of Professional Regulation) testi- 475 (1945) (lack of justiciable controversy found in light fied that based upon various decisions in the abortion of agreement not to enforce challenged state law). area, this section was not being enforced. The plaintiffs did not introduce any evidence to the contrary. The majority's assumption of jurisdiction over the unen- forced provisions in this case is not only in conflict with The defendants argued below that in light of the policies the foregoing decisions regarding justiciability standards, of nonenforcement which were articulated by the regula- but also with certain decisions governing the jurisdictional tory agencies and entered into evidence, plaintiffs had not bar created by the Eleventh Amendment. That amendment presented a justiciable controversy as to certain chal- limits the power of federal courts to grant relief in cases lenged provisions. However, the majority opinion utilized where there are no ongoing violations of federal law. a mootness analysis with respect to those nonenforced pro- Green v. Mansour, 474 U.S. 64, 71 (1985). That limita- visions. The majority concluded that plaintiffs' challenge tion is applicable even in those instances where mootness to the second trimester hospitalization requirement (ASTC is at issue. Watkins v. Blinzinger, 789 F.2d 474, 484 (7th Regulation Section 205.740) (App. 222) was moot. The chal- Cir. 1986). Thus, even if an underlying claim is not moot, lenges to the other unenforced provisions, however, were the Eleventh Amendment bars further proceedings in fed- not found to be moot. eral court where there is no continuing conduct the State Preliminarily, however, a mootness analysis is not appro- must change to comply with federal law. Id. According- priate in this context. Mootness issues arise when a chal- ly, the majority's assumption of jurisdiction over unen- lenged policy changes after the commencement of litiga- forced provisions is in conflict with decisions governing tion. Here, the enforcement policies are based on court justiciability standards and with decisions dealing with decisions and determinations which pre-date this lawsuit. Eleventh Amendment standards because there is no on- going violation of federal law. It is axiomatic that the court must look to the state of affairs as of the filing of the complaint in determining -24- -25- B. performed under conditions that insure maximum safety." THE MAJORITY OPINION ERRONEOUSLY FOUND (App. 149). THAT THE CHALLENGED STATUTES AND REGULA- TONS VIOLATE THE CONSTITUTIONAL RIGHT TO Thus, two other courts of appeals have upheld licensing PRIVACY. standards of outpatient surgical facilities in which preg- nancy terminations are performed. Baird v. Department The majority opinion affirmed the district court's exemp- of Public Health, 599 F.2d 1098, 1102 (1st Cir. 1979) tion of abortion procedures from the licensure and regu- ("There is room under Roe for states to apply the same latory provisions which generally apply to outpatient licensing standards to abortion facilities as they apply to surgical facilities. In addition, the majority held that "the like facilities performing medically analogous procedures."); State may not require separate licensure of facilities pri- Hodgson v. Lawson, 542 F.2d 1350, 1358 (8th Cir. 1976) marily devoted to performing abortions." The majority ("A state can impose the same regulations on a clinic, spe- opinion is in conflict with decisions of this Court and other cifically built to perform abortions during the first tri- courts of appeals as to the authority of the State to li- mester, that are imposed on other clinics that perform cense and regulate outpatient surgical facilities in which surgical procedures requiring approximately the same pregnancy terminations are performed. The State has the degree of skill and care as the performance of first tri- duty and authority to license and regulate such facilities mester abortions."). in the same manner as facilities in which other outpatient surgical procedures are performed. In this case, the HFP Act and the ASTC Act, as en- forced, are abortion-neutral and are applicable to all li- This Court has consistently held, even with respect to censed ASTCs, irrespective of the types of surgical pro- first trimester abortions, that the State has an interest cedures performed. These statutes were clearly enacted in making sure that certain factual assumptions made in to further the State's interests in regulating the ever in- Roe v. Wade, 410 U.S. 113 (1973) continue to exist. As creasing number of outpatient surgical facilities. The State explained in City of Akron v. Akron Center for Reproduc- has responsibilities to its citizens to insure that medical tive Health, Inc., 462 U.S. 416, 430 n.12 (1983): procedures performed at these facilities are performed un- Of course, the State retains an interest in ensuring der circumstances enhancing their safety. Further, the the validity of Roe's factual assumption that "the State can legitimately seek to establish a comprehensive first trimester abortion [is] as safe for the woman as and less costly health care delivery system. Those re- normal childbirth at term," an assumption that "holds true only if the abortion is performed by medically sponsibilities do not cease when an abortion is the surgical competent personnel under conditions insuring maxi- procedure which is to be performed. mum safety for the woman." Connecticut v. Menillo, In addition, the majority rejected the argument that 423 U.S. 9, 11, 46 L.Ed.2d 152, 96 S.Ct. 170 (1975) abortion-neutral regulations should be scrutinized under (per curiam). a different standard than abortion-specific regulations. De- The ASTC Act seeks to effectuate that interest by "assur- fendants maintain that such argument is clearly supported ing that all medical procedures, including abortions, are by the two previously cited opinions from the First and Eighth Circuit Courts of Appeals. Accord, Westchester -26- -27- Women's Health Org. v. Whalen, 475 F.Supp. 734 (S.D. N.Y. 1979) (requirements governing "diagnostic and treat- ity opinion states that Dr. Ragsdale's estimated com- ment centers" applicable to facilities performing first tri- pliance with the regulations would entail a per patient mester abortions); Abortion Coalition of Mich. Inc. v. cost of between $25 and $40 (App. 22), the actual testi- Mich. Dep't of Public Health, 426 F.Supp. 471 (E.D. Mich. mony was that reasonable compliance would only result 1977) (requirements for "free standing surgical outpatient in an estimated $25.21 per patient fee increase. That in- facilities" applicable to facilities performing first trimester crease would be reduced to $10.90 after two years and abortions). $3.40 after five years due to the retirement of certain debts. This increase is de minimis and did not sustain The argument that abortion-neutral regulations should plaintiffs' burden of proof even under the standards found be scrutinized under a less exacting standard than abor- applicable by the majority. (App. 23). tion-specific regulations is also supported by decisions of this Court in other contexts. City of Renton v. Playtime For example, in Planned Parenthood Ass'n v. Ashcroft, Theatres, Inc., 475 U.S. 41, 46-47 (1986) (standards under 462 U.S. 476 (1983), this Court considered the impact on First Amendment for "content-based" and "content-neu- the woman's exercise of her right to decide whether to tral" zoning regulations); Minneapolis Star & Tribune Co. have an abortion caused by the cost of a State required v. Minn. Comm'n of Revenue, 460 U.S. 575, 582-83 (1983) pathology report. This Court held that the estimated cost (standards under First Amendment for general and special of $19.40 per patient did not "significantly burden a preg- taxes as applied to the press). Accord, Arcara v. Cloud nant woman's abortion decision." Id. at 490. Books, Inc., 478 U.S. 697, 106 S.Ct. 3172, 3177 (1986) Similarly, in the instant matter, plaintiffs' cost estimates (First Amendment is not implicated by the enforcement did not establish a "sufficiently substantial" interference of a public health regulation of general application against with a pregnancy termination decision. Thus, the lower the physical premises in which sexually explicit books and courts erred in applying a strict scrutiny standard to the magazines are sold). Thus, defendants maintain that the challenged provisions, and in determining that those pro- lower courts applied an erroneous legal standard to the visions were invalid under that standard. abortion-neutral provisions. Even if the strict scrutiny test was correctly determined to apply, the majority erred in determining that plain- tiffs had established a sufficiently substantial interference with the abortion decision. The majority opinion misappre- hended the testimony regarding the purported cost of 2 continued compliance with the State regulations.2 While the major- cost estimates, without objection. (App. 22). As correctly stated in the dissenting opinion, "the defendants objected throughout the 2 The majority opinion also incorrectly found that Dr. Ragsdale hearing as to the relevancy and admissibility of Ragsdale's alleged was permitted to testify as to the substance of his handwritten cost sheets" (App. 67). At the outset, defendants objected to any (Footnote continued on following page) use of those documents. Further objections were raised when plaintiffs moved for their admission into evidence. -28- -29- C. As this Court has noted, a court should refrain from THE MAJORITY OPINION CONFLICTS WITH DECI- invalidating more of a statute than is necessary. Regan SIONS OF THIS COURT REGARDING SEVERANCE OF v. Time, Inc., 468 U.S. 641, 652 (1984). It is, moreover, PURPORTEDLY UNCONSTITUTIONAL PROVISIONS. the duty of the court to "maintain the act in SO far as Assuming, arguendo, that the lower courts appropriately it is valid." Id. at 652, quoting El Paso & Northeastern assumed jurisdiction over the challenged provisions which R. Co. v. Gutierrez, 215 U.S. 87, 96 (1909). Likewise, this are not being enforced, those courts should have severed Court has held that "fu]nless it is evident that the Legis- any purportedly unconstitutional statutes or regulations. lature would not have enacted those provisions which are For instance, the abortion-specific language of par. 157-8.3 within its power, independently of that which is not, the of the ASTC Act has not been enforced since 1981 due invalid part may be dropped if what is left is fully oper- to the decision of the Illinois Supreme Court in Village ative as a law." Buckley v. Valeo, 424 U.S. 1, 108-09 of Oak Lawn v. Marcowitz, 86 III.2d 406 (1981). In that (1976), quoting Champlin Refining Co. v. Corporation case, the court struck down a portion of a local ordinance Commission, 286 U.S. 210, 234 (1932). that incorporated the ASTC Act definition of an ASTC. Given the ASTC Act's declared purpose of assuring that The disputed portion covered "any facility where a medi- all medical procedures, including abortion be performed cal or surgical procedure is performed for the termina- under circumstances insuring maximum safety, the Su- tion of pregnancy, regardless of whether the facility is preme Court of Illinois' holding on severability in Marco- primarily devoted to that purpose." Id. at 420. The court witz, and the State's policy of nonenforcement, there is severed that portion, but found the remaining portion of no doubt that the abortion-specific language of the ASTC the ordinance to be "complete in itself and susceptible Act should have been severed if declared unconstitutional. to independent enforcement." Id. at 421. Likewise, any purportedly unconstitutional provisions of In the instant appeal, the majority opinion rejected the the HFP Act and the ASTC regulations should have been argument that any purportedly unconstitutional provision severed. By failing to appropriately address the severabil- be severed. It characterized the regulatory scheme as be- ity issue, the majority opinion has improperly frustrated ing "so riddled with exceptions resulting from judicial the intent of the elected representatives of the people decisions and nonenforcement policies as to be unintelligi- of the State of Illinois. Regan v. Time, Inc., 468 U.S. at 653. ble." (App. 33). Defendants submit that a court should focus upon the provisions independently and on their own merit. Other- wise, litigants will be encouraged to base their litigation strategy upon the sheer number or volume of statutes and regulations to be attacked on constitutional grounds. The more broad based the attack, the greater the purported burden on constitutional guarantees. No. 88-790 FILED In The JAN 13 1900 Supreme Court of the United Statement JOSEPH F. SPANKS October Term, 1988 BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illinois Department of Public Health, et al., Appellants, v. RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From the United States Court of Appeals For the Seventh Circuit MOTION TO DISMISS OR AFFIRM ALAN S. GILBERT COLLEEN K. CONNELL LORIE A. CHAITEN (Counsel of Record) SONNENSCHEIN CARLIN NATH ROGER BALDWIN FOUNDATION & ROSENTHAL OF ACLU OF ILLINOIS 8000 Sears Tower Suite 1600 233 S. Wacker Drive 20 E. Jackson Blvd. Chicago, IL 60606 Chicago, IL 60604 (312) 876-8000 (312) 427-7330 Pandick Tochnologies, Inc., Chicago (312) 236-0200 QUESTION PRESENTED Whether the Court of Appeals correctly affirmed a preliminary injunction, based on factual findings entered after an expedited hearing, prohibiting the enforcement against plaintiffs of three Illinois statutes intended to restrict the performance of early abortions to "the functional equivalent of small hospitals," and which the Court of Appeals found burdened the abortion right without any "medical justification whatsoever"? ii iii PARTIES TO THE PROCEEDINGS TABLE OF CONTENTS Page (See Jurisdictional Statement)" QUESTION PRESENTED i PARTIES TO THE PROCEEDINGS ii TABLE OF CONTENTS iii TABLE OF AUTHORITIES V OPINIONS BELOW 1 CONSTITUTIONAL, STATUTORY AND REGULATORY PROVISIONS INVOLVED 1 STATEMENT OF THE CASE 2 REASONS FOR DISMISSING THE APPEAL OR IN THE ALTERNATIVE AFFIRMING THE JUDGMENT BELOW 5 1. THIS COURT LACKS MANDATORY JURISDICTION AND SHOULD NOT EXERCISE ITS DISCRETIONARY JURISDICTION TO REVIEW THIS AFFIRMANCE OF A PRELIMINARY INJUNCTION ORDER WITHOUT A FULL AND FINAL RESOLUTION OF ALL FEDERAL ISSUES BY THE LOWER Pursuant to Rule 28.1 of the Supreme Court Rules. plaintiffs state FEDERAL COURTS 5 that the Northern Illinois Women's Center is a medical corporation wholly owned by Richard Ragsdale, M.D., and has no parent, no subsidiaries and no affiliate corporations. iv > II. NO ISSUES OF EXCEPTIONAL TABLE OF AUTHORITIES IMPORTANCE ARE PRESENTED FOR REVIEW 8 Cases: Pages Abortion Coalition of Michigan, Inc. V. Michigan A. The Court Of Appeals' Decision Replicates Dep't of Public Health, 426 F. Supp. 471 (E.D. Recent Decisions Of This Court And Is In Mich. 1977) 10 Accord With Decisions Of Other Courts Of Appeals That Have Enjoined Regulatory Alabama State Federation of Labor V. McAdory, Schemes That Burden The Abortion Right. 8 325 U.S. 450 (1945) 19 B. The Court Of Appeals Correctly Applied Legal Standards Established By This Court Baird v. Department of Public Health, 599 F.2d For Review Of Provisions Affecting The 1098 (1st Cir. 1979) 11 Fundamental Right Of Abortion During The Early Stages Of Pregnancy 11 Birth Control Centers, Inc. V. Reizen, 508 F. Supp. 1366 (E.D. Mich. 1981), aff d in part, C. The Decision Below Is Consistent With vacated in part, 743 F.2d 352 (6th Cir. 1984) 10 This Court's Decisions In The Areas Of Justiciable Controversies And Severability. 18 Birth Control Centers, Inc. V. Reizen, 743 F.2d 352 (6th Cir. 1984) 9, 10 1. In Light Of Defendants' Continuing Policy Of Enforcement, The Court Of Buckley V. Valeo, 424 U.S. I (1976) (per Appeals Appropriately Affirmed The curiam) 21 Preliminary Injunction 18 Champlin Refining Co. V. Corporation 2. The Court Of Appeals Properly Commission, 286 U.S. 210 (1932) 21 Enjoined The Entire Regulatory Scheme As It Applies To Early Abortion Charles V. Daley, 749 F.2d 452 (7th Cir. 1984), Services 20 appeal dism'd sub nom., Diamond V. Charles, 19 476 U.S. 54 (1986) CONCLUSION 22 C.I.O. V. McAdory, 325 U.S. 472 (1945) 19 vi vii City of Akron V. Akron Center for Reproductive Indiana Hospital Licensing Council V. Women's Health, Inc., 462 U.S. 416 (1983) 8, 10, 11, Pavilion, 420 N.E.2d 1301 (Ind. App. 1981) 9 12, 17 J.N.S. V. State of Indiana, 712 F.2d 303 (7th City of Los Angeles V. Lyons. 461 U.S. 95 Cir. 1983) 19 (1983). 19 Mahoning Women's Center V. Hunter, 610 F.2d City of Mesquite V. Aladdin's Castle, Inc., 455 456 (6th Cir. 1979), vacated on other grounds, U.S. 283 (1982). 19 447 U.S. 918 (1980) (mem.) 9, 21 Connecticut V. Menillo, 423 U.S. 9 (1975) (per Minneapolis Star & Tribune Co. V. Minn. curiam) 11 Comm'r of Revenue, 460 U.S. 575 (1983) 17 Doe V. Bolton, 410 U.S. 179 (1973) 4 Planned Parenthood of Central Missouri V. Danforth, 428 U.S. 52 (1976) 11, 14 Ex Parte Young, 209 U.S. 123 (1908) 20 Poe V. Ullman, 367 U.S. 497 (1961) 19 Fox Valley Reproductive Health Care Center, Inc. V. Arft, 446 F. Supp. 1072 (E.D. Wis. Ragsdale V. Turnock, 625 F. Supp. 1212 (N.D. 1978) 9 III. 1985), aff d in part, vacated in part, 841 F.2d 1358 (1988). 10 Friendship Medical Center, Ltd. V. Chicago Bd. of Health, 505 F.2d 1141 (7th Cir. 1974), cert. Ragsdale V. Turnock, 841 F.2d 1358 (7th Cir. denied, 420 U.S. 997 (1975) 9 1988) passim Green V. Mansour, 474 U.S. 64 (1985) 20 Regan V. Time, Inc. 468 U.S. 641 (1984) 21 Hodgson V. Lawson, 542 F.2d 1350 (8th Cir. Roe V. Wade, 410 U.S. 113 (1973) 10, 11, 1976) (per curiam) 10, 11 12, 17 Hodgson V. Lawson, No. 4-74-155 (D. Minn., Simopoulos V. Virginia, 462 U.S. 506 (1983) 10 March 7, 1977) 11 viii ix Socialist Labor Party V. Gilligan, 406 U.S. 583 (1972). STATUTES 7 Thornburgh V. American College of Obstetricians 28 U.S.C. Section 1254(2) 5, 6, 18 & Gynecologists, 476 U.S. 747 (1986) 5, 7, 8, Ambulatory Surgical Treatment Center Act, III. 12, 13, Rev. Stat. ch. 111 1/2, par. 157-8.1 et seq. 16 (1983). passim United States V. Carolene Products Co., 304 U.S. 144 (1938) Medical Practice Act, III. Rev. Stat. ch. 111 par. 6 4433 (1983). passim Watkins V. Blinzinger, 789 F.2d 474 (7th Cir. 1986), cert. denied, - U.S. - 107 S. Ct. Health Facilities Planning Act, III. Rev. Stat. ch. 1976 (1987). 111 1/2, par. 1151 et seq. (1983) passim 20 Westchester Women's Health Organization, Inc. REGULATIONS V. Whalen, 475 F. Supp. 734 (S.D.N.Y. 1979). 11 Ambulatory Surgical Treatment Center Licensing Requirements, 77 III. Adm. Code, Chapter 1, Wisconsin V. Yoder, 406 U.S. 205 (1972) 6, 17 Subchapter b, Part 205. passim CONSTITUTIONAL PROVISIONS U.S. Const. Amend. I passim U.S. Const. Amend. IV passim U.S. Const. Amend. V passim U.S. Const. Amend. IX. passim U.S. Const. Amend. XI. passim U.S. Const. Amend. XIV, Section 1 passim OPINIONS BELOW (See Jurisdictional Statement) CONSTITUTIONAL STATUTORY AND REGULATORY PROVISIONS INVOLVED (See Jurisdictional Statement) MOTION TO DISMISS OR AFFIRM The United States Court of Appeals for the Seventh Circuit affirmed a preliminary injunction prohibiting the enforcement against plaintiffs of Illinois laws that operate together to require that all first and early second trimester abortions be performed in specially licensed facilities that are 'the functional equivalent of small hospitals.'" App. 19 (citation omitted). The Court of Appeals based its decision on District Court factual findings that the challenged statutes burdened the abortion right without any "medical justification whatsoever." App. 29. The interlocutory decision below is not a final order subject to review under this Court's mandatory appeal jurisdiction. Review under a writ of certiorari also is inappropriate. The Court of Appeals' decision adheres closely to, and to a great extent replicates, prior Supreme Court decisions. Defendants offer no reason to disturb this precedent. Nor do defendants present any conflict or important federal question that warrants the Court's consideration at this interlocutory juncture. 2 3 STATEMENT OF THE CASE The ASTC Act does not single out any type of surgical procedure, other than abortion, for special regulation. While As the courts below found, the challenged statutes are defendants posit benevolent "general" health regulations, directed at providers of abortion services and are, in large applied even-handedly to all health care providers (Juris. St. part, intended to restrict abortion services. App. 21. As 24-25), such a regulatory scheme simply is not at issue here. drafted, the Ambulatory Surgical Treatment Center Act ("ASTC Act") requires special licensure of all ASTCs. The trial court below concluded, as a matter of fact, and which, by definition, include "any place or building the Court of Appeals affirmed as not clearly erroneous, that devoted primarily to the performance of surgical the tripartite regulatory scheme burdened, without medical procedures" and "any facility in which a medical or surgical justification, the rights of women to choose to have first and procedure is utilized to terminate a pregnancy, irrespective of early second trimester abortions. The challenged statutes whether the facility is devoted primarily to this drive up the cost of each abortion procedure; substantially purpose III. Rev. Stat. ch. 111 1/2, § 157-8.3(A) impede women who seek access to abortion services; and (emphasis added)¹. prevent potential health care providers from offering abortions because the cost of compliance is "prohibitive." App. 22-23, 31. Defendants failed 10 supply any evidence that the statutory provisions either enhanced the safety of I The ASTC Act provides that failure to obtain an ASTC license early abortion procedures or protected the pregnant woman's constitutes a business offense punishable by a fine of $10,000 per day. health. App. 29-30. Indeed, rather than "protect[ing] public Id. at § 157-8.12. Section 16-1 of the Medical Practice Act ("MPA"), health" (Juris. St. 5), the challenged scheme actually proved III. Rev. Stat. ch. 111, § 4433(1), provides the second link of the to be harmful, from a medical standpoint, for some women scheme and grants employees of the Illinois Department of Registration seeking abortions. App. 27-28. and Education ("DRE") "absolute prosecutorial discretion" (Defendant's Jurisdictional Statement at 10) to revoke or suspend the license of any physician who performs even one first trimester abortion outside of a Thus, the Court of Appeals affirmed the District Court's hospital or licensed ASTC. The Health Facilities Planning Act preliminary injunction, applying established Supreme Court ("HFPA"), III. Rev. Stat. ch. 111 1/2, § 1151 et. seq., provides the precedent, which directs that when a state statute, whether final link and requires ASTCs, like hospitals, to submit to the lengthy abortion-neutral or abortion-specific, burdens the exercise of public hearings and potential public veto of the certificate of need a woman's decision to have an abortion, that statute can ("CON") process prior to constructing, renovating, or relocating their withstand constitutional scrutiny only if it is justified by a facilities. compelling governmental interest and is carefully crafted to References to defendants' Jurisdictional Statement appear as "Juris. SL" advance that interest. In addition, the Court of Appeals References to the Court of Appeals' opinion and other documents from indicated that this scheme lacked even a reasonable basis. defendants' Appendix 10 Jurisdictional Statement appear as "App." App. 24. References to the trial transcript appear as "Tr." or "Dep." 4 5 Defendants' contention that the decision below "has exempted outpatient surgical facilities in which abortions are REASONS FOR DISMISSING THE APPEAL performed from general licensure and regulatory provisions" OR IN THE ALTERNATIVE AFFIRMING (Juris. St. 21) is belied by the express terms of the THE JUDGMENT BELOW. injunction issued. Contrary to defendants' claim that the decision below "emasculates" the State's general authority to 1. THIS COURT LACKS MANDATORY regulate physicians or outpatient medical facilities (Juris. St. JURISDICTION AND SHOULD NOT 21), the injunction left the defendants free to apply their EXERCISE ITS DISCRETIONARY regulatory scheme to non-abortion medical procedures, even JURISDICTION TO REVIEW THIS when abortion and non-abortion procedures are performed in AFFIRMANCE OF A PRELIMINARY the same facility. App. 110-11. The State also remains free INJUNCTION ORDER WITHOUT A to enforce against physicians who perform abortions the FULL AND FINAL RESOLUTION OF professional censure and licensing provisions of the MPA, ALL FEDERAL ISSUES BY THE LOWER for with the exception of Section 16-1, which requires FEDERAL COURTS. abortions to be performed in ASTCs, the MPA was not challenged. Compare Doe V. Bolton, 410 U.S. 179, 200 In their attempt to attract this Court's attention under its (1973). Further, even facilities exclusively devoted to waning mandatory jurisdiction, defendants overlook a abortion practice remain subject to general state and local fundamental prerequisite to the exercise of such jurisdiction. safety regulations such as fire and building codes. Under 28 U.S.C. § 1254(2), Supreme Court jurisdiction exists only to review a final judgment by the court of appeals Thus the courts below preliminarily enjoined the declaring a state statute invalid as repugnant to the challenged statutory scheme, but did so only insofar as Constitution. Thornburgh V. American College of necessary to protect the constitutional rights of women Obstetricians & Gynecologists, 476 U.S. 747, 754-755 seeking first and early second trimester abortion procedures. (1986). In this case, the District Court held its hearing on an expedited basis in response to plaintiffs' plea that preliminary injunctive relief issue before the threatened termination of Dr. Ragsdale's medical practice when his lease expired on December 31, 1985. (Juris St. 5); App. 118. As defendants themselves acknowledge, the injunction the Court of Appeals affirmed was preliminary in nature. (Juris. St. 1, 14, 16.) This interlocutory judgment is not a final judgment within "the ordinary meaning of that term." Thornburgh, 476 U.S. at 754 (dismissing state appeal of 6 7 preliminary injunction of abortion law). Thus, defendants' stage. Review by this Court now would be limited to the attempt to invoke this Court's mandatory jurisdiction is question of whether the preliminary injunction constituted an premature. abuse of the District Court's discretion and whether the District Court's factual findings, subject to change based on The concerns about premature review which underlie the future factual development, were clearly erroneous.² finality requirement of § 1254(2) further caution against the grant of a writ of certiorari to review this preliminary "Problems of prematurity and abstractness may well injunction. Although plaintiffs filed suit on behalf of a class present 'insuperable obstacles' to the exercise of the Court's of physicians and a class of Illinois women, the preliminary jurisdiction. Socialist Labor Party V. Gilligan. 406 injunction hearing focused primarily on Dr. Ragsdale's need U.S. 583, 588 (1972) (citation omitted). Thus, in the past. for immediate relief. (Tr. 20.) The District Court made clear even where jurisdiction technically existed, this Court has that, given the emergency nature of Dr. Ragsdale's case, it declined to exercise it "unless the case 'tenders the was conducting only a "preliminary injunction hearing and underlying constitutional issues in clean-cut and concrete not a final injunction [hearing]." (Tr. 622.) The Court, as form." Id. (citation omitted). well as the parties, anticipated that a more complete evidentiary record would be made at a future permanent injunction hearing. (See Tr. 20, 531, 622.) Nowhere is the need for such factual development more important than in the adjudication of fundamental rights, such as the right to privacy. See United States V. Carolene Products Co., 304 U.S. 144, 152 n.4 (1938); see generally Wisconsin V. Yoder, 406 U.S. 205, 209-213 (1972). Further fact-finding may have a profound impact upon the rulings made by the lower federal courts on the constitutionality of the Illinois statutes and thereby sharpen the presentation of the ultimate issues should the case come before this Court at some future date. 2 In Thornburgh, which held that mandatory jurisdiction exists only to review final judgments, this Court exercised its certioran jurisdiction In addition, as shown below, the Court of Appeals' to review the preliminary injunction imposed by the Court of Appeals after the trial court had denied injunctive relief. Thornburgh. 476 U.S. decision follows closely the directives of this Court with at 755. There, the District Court had analyzed a facial challenge to an regard to regulation of early abortion services. As a result, abortion statute based on a supulated record. Id. By way of contrast, defendants cannot support their contention that this case the District Count here made preliminary findings on a contested facual presents issues important enough to warrant review at this record in an as-applied challenge. 8 9 II. NO ISSUES OF EXCEPTIONAL most courts that have examined comprehensive regulatory IMPORTANCE ARE PRESENTED FOR REVIEW. schemes, either specifically directed at abortion services in the early stages of pregnancy or general in nature but having an impact on the abortion right, have found that such A. The Court Of Appeals' Decision regulations unconstitutionally interfere with a woman's Replicates Recent Decisions Of This fundamental right to make and effectuate the decision to Court And Is In Accord With terminate a pregnancy. See, e.g., Birth Control Centers, Decisions Of Other Courts of Appeals Inc. V. Reizen, 743 F.2d 352, 364-65 (6th Cir. 1984) That Have Enjoined Regulatory (staffing, structural and equipment requirements, similar to Schemes That Burden The Abortion those challenged here, declared unconstitutional because Right. compliance would be difficult and would increase the cost of each individual abortion); Mahoning Women's Center V. The case at bar is not of exceptional importance meriting Hunter 610 F.2d 456, 458-60 (6th Cir. 1979). vacated on review because the decision below merely replicates this Court's decisions in City of Akron V. Akron Center For other grounds, 447 U.S. 918 (1980) (mem.) (city ordinance that required first trimester abortions to be performed in Reproductive Health, Inc., 462 U.S. 416 (1983), and clinics nearly identical to hospital surgical wards found Thornburgh, 476 U.S. 747. Contrary to the inference left unconstitutional); Friendship Medical Center, Ltd. V. by defendants (Juris St. 24), this Court did not uphold a Chicago Bd. of Health, 505 F.2d 1141, 1144-45 (7th Cir. comprehensive licensing and regulatory scheme in Akron. Instead, in Akron, and again in Thornburgh, this Court held 1974), cert. denied, 420 U.S. 997 (1975) (regulatory scheme imposed upon first trimester abortion providers, that health and safety regulations that burden the abortion remarkably similar to the tripartite scheme the State defends right without medical justification are unconstitutional. See here, found unconstitutional). See also Fox Valley Akron, 462 U.S. 416 (health regulations restricting second Reproductive Health Care Center, Inc. V. Arft, 446 trimester abortions to hospital are unconstitutional); F. Supp. 1072, 1074-75 (E.D. Wis. 1978) (general clinic Thornburgh, 476 U.S. at 763, 765-66 (counseling licensing provisions preliminarily enjoined as applied to first regulations which limit physician's professional discretion trimester abortion provider because of "burdensome requirements). are unconstitutional, as are abortion-specific reporting interference"); Indiana Hospital Licensing Council V. Women's Pavilion, 420 N.E.2d 1301 (Ind. App. 1981) Other courts of appeals, in cases defendants do not cite, have displayed little difficulty in applying this Court's precedents to enjoin similar state attempts to burden providers of first and early second trimester abortions through purported health and safety regulations. Indeed, 10 11 (licensing scheme found impermissibly to burden right to of a woman to choose to have an abortion. Hodgson v. first trimester abortion).³ Lawson, No. 4-74-155 (D. Minn., March 7, 1977). Defendants overlook this unequivocal support for the B. The Court Of Appeals Correctly Court of Appeals' decision and rely instead on cases that Applied Legal Standards Established have been superseded by more recent authoritative decisions. By This Court For Review Of Defendants' reliance on Abortion Coalition of Michigan, Inc. Provisions Affecting The V. Michigan Dep't of Public Health, 426 F. Supp. 471 Fundamental Right Of Abortion (E.D. Mich. 1977) (Juris. St. 26), is particularly During The Early Stages of inappropriate because the regulations at issue were struck Pregnancy. down later in Reizen, 743 F.2d 352, a post-Akron decision.4 Hodgson V. Lawson, 542 F.2d 1350 (8th Cir. State regulation of abortion during the first and early 1976) (per curiam) (Juris. St. 25), is similarly inapposite. second trimesters of pregnancy is constitutionally In Hodgson, the court stated its approval of a requirement, permissible only if: 1) such regulation does not in any way clearly invalid after this Court's 1983 decision in Akron, that burden the abortion decision or its effectuation, see Planned all second trimester abortions be performed in hospitals. Parenthood of Central Missouri V. Danforth, 428 U.S. 52 542 F.2d at 1354. Moreover, on remand for an evidentiary (1976); or 2) the regulation is integral to the procedure, as hearing, the three-judge District Court held unconstitutional contemplated by the Roe decision. See Connecticut V. the regulations, like those at issue here, found to impose Menillo, 423 U.S. 9 (1975) (per curiam) (Court upheld significant and unjustified burdens on the fundamental right statute requiring that abortions be performed by licensed 5 Westchester Women's Health Organization V. Whalen, 475 3 Simopoulos V. Virginia, 462 U.S. 506 (1983). is not to the F. Supp. 734 (S.D.N.Y. 1979), also cited by defendants (Juris. St. 26), contrary. In Simopoulos, this Court upheld only state regulation of a is of doubtful validity, having approved a second trimester late second trimester abortion performed at 22 weeks of pregnancy. 462 hospitalization requirement. The Wesichester court, unlike this Court U.S. at 508, 510 n.2. At this advanced stage of pregnancy, a state's in Akron. failed to consider an increase in cost as an unconstitutional interest in the health of the woman becomes compelling. Roe V. Wade, burden to the effectuation of the abortion decision. The First Circuit's 410 U.S. 113, 163 (1973); see also App. 19 n.8. decision in Baird V. Department of Public Health, 599 F.2d 1098 (1st Cir. 1979). upon which defendants also rely (Juris. St. 25), suffers 4 See Reizen, 508 F. Supp. 1366, 1369 n.1 (E.D. Mich. 1981), aff d from the same flaw as the Eighth Circuit's decision in Hodgson. That in part, rev'd in part, 743 F.2d 352 (6th Cir. 1984) (stating that the case, which upheld a regulatory scheme, was decided on a stipulated challenged provisions are identical to those in Abortion Coalition): see record with no evidence of the impact on a fundamental right or of the also Ragsdale V. Turnock, 625 F. Supp. 1212, 1229 n.22 (1985): App. safety of the abortion procedure as compared to other surgical 144-45 (same). procedures. Compare App. 21. 12 13 physicians because Roe contemplated that physician would be integral part of abortion process). Thus, during the early Each of the three physicians who testified as an expert stages of pregnancy, a "woman must be permitted, in witness at trial, including the defendants' expert, testified consultation with her physician, to decide to have an emphatically that first and early second trimester abortions abortion and to effectuate that decision 'free of interference are among the safest of outpatient procedures. Contrary to by the State." Akron 462 U.S. at 429-30, (quoting Roe, the defendants' implications (Juris. St. 8-9), these 410 U.S. at 163). physicians testified that the State had no legitimate medical reason to single out abortion providers for the imposition of Where, as here, the evidence demonstrates that a an additional layer of regulation. (Barton, Dep. 95-96, 174, regulatory scheme significantly burdens first and early Tr. 466, 475; Ragsdale, Tr. 66-68, 80; Hern, Tr. 238-42, second trimester abortions, the State must show, by strict 274, 279.) See also App. 30.7 factual proof, that such regulation is necessary to the safe performance of the abortion procedure. See Thornburgh, The factual findings further demonstrate that the 476 U.S. at 759.6 As this Court repeatedly has warned, regulatory provisions imposed under the ASTC Act, "[t]he States are not free, under the guise of protecting particularly the costly physical plant requirements, "do not maternal health," to create obstacles that burden a woman's have 'any medical justification." App. 29 (citations to the effectuation of her decision to have an abortion. Id. at 759. record omitted). Indeed some of the provisions were shown The Court of Appeals' decision adheres to this well-settled to be "medically poor." App. 29. Thus, as the courts below principle, which defendants show no reason to disturb. found, this scheme imposes requirements that force first trimester abortion providers to incur the great costs of As discussed above, the abortion-directed regulatory building "small hospitals," yet fails to further the safety of scheme here significantly burdens the ability of a woman to the procedure. App. 29. effectuate her choice to have an abortion. In addition, defendants failed to offer any justification to support the burdensome scheme. 7 Nonetheless, defendants continue to defend the statutory scheme, 6 Medical technology now has made early second trimester abortions, especially the ASTC Act, with its abortion-specific subparts, as as well as first trimester abortions, extremely safe. Akron, 462 U.S. at medically necessary. Among the provisions lauded by defendants (Juris. 429 n.11, see also App. 16, 20 n.8. Thus, the Court has struck down St. 12) is a counseling requirement nearly identical to that struck in purported health regulations burdening early second trimester procedures Thornburgh. The ASTC regulations demand that each woman, even if in the same manner as il has struck regulations burdening first trimester faced with a life-threatening pregnancy. be advised of the alternatives to procedures. This Court has recognized that States may have a abortion, although that information might well, as found by the Court compelling interest in applying narrowly tailored regulations only in of Appeals, "be cruel as well as destructive of the physician-patient the later stages of pregnancy. Akron, 462 U.S. at 427. relationship." App. 27-28, (quoting Thornburgh, 476 U.S. at 763). 14 15 Defendants' presentation of this complex regulatory scheme obscures all but its most innocent provisions. judgment" for each individual woman. App. 27.8 Further, (Juris. St. 11-14.) Defendants disregard all of the essential the cost of compliance with these onerous requirements was requirements for licensing that impose significant burdens. found to be prohibitive to potential abortion providers, as See Ambulatory Surgical Treatment Center Licensing well as to women seeking early abortions. App. 22-23.9 Requirements, 77 III. Adm. Code, Chapter 1, Subchapter b, Part 205. For example, a facility must have, among other Defendants' assertion of a general regulatory objective things: (a) a procedure room that is the same size as that that "all medical procedures, including abortions, [be] recommended for a tertiary care hospital, Section performed under conditions that insure maximum safety''' 205.1360(b); App. 232; (b) a "control station" located to (Juris. St. 24-25 (citation omitted]) will not support this allow visual surveillance of traffic entering the operating burdensome regulatory scheme. As the Court of Appeals suite, Section 205.1370(a); App. 233; and (c) an elaborate found, the ASTC Act "was enacted primarily with abortion air-conditioning, heating and ventilation system to provide specified filter efficiencies and airflow relationships between rooms that would be found in a sophisticated operating room 8 The American College of Obstetricians & Gynecologists' Standards suite in a complete care hospital. Section 205.1540; App. for Obstetric-Gynecological Services, Sixth Edition, explicitly approves 242-43; see also App. 5. By the admission of the State's the performance of first and early second trimester abortions in a physician's office, the specifications of which are left to the doctor's own witnesses, these and other burdensome requirements professional discretion. (ACOG Standards 60, 64 [6th Ed. 1985].) were designed to accommodate major surgical procedures, Defendants seriously misconstrue these standards with their claim that not minor procedures such as early abortions. (Linder, Dep. ACOG recommends uniformly applying the hospital-like standards 48; Ramsay, Tr. 764.) established in the ASTC Act to first and early second trimester abortion procedures. (Juris. St. 12.) Although a few regulations are, as defendants suggest, 9 Defendants' contention that "reasonable compliance" with the consistent with medical standards for abortion providers, the regulatory scheme would increase the cost of each abortion by only a cumulative effect of the ASTC Act, which defendants moderate amount (Juris. St. 27) disregards the District Court's factual ignore, is to regulate every minute facet of a first or early finding, affirmed by the Court of Appeals, that compliance would second trimester procedure. App 23-25. As a result, increase the cost per procedure by almost 100 percent more than physicians are locked into a statutory "straitjacket," see defendants' claimed amount Id. Defendants do not define "reasonable Danforth, 428 U.S. 52, 67 n.8, which denies them the compliance" nor does the statute specify a consistent standard of required compliance. Indeed, the evidence introduced at trial shows that professional flexibility needed to make the "best medical defendants demand inconsistent levels of compliance. For example, prior to termination of Dr. Ragsdale's lease, his facility had been licensed as "substantially complying;'" however, "officials charged with enforcing the regulations told Dr. Ragsdale that they would require `considerably more substantial compliance" when he moved to a new facility. App 9-10. 16 17 clinics in mind. App. 21. In Thornburgh, the Court abortion-neutral or abortion-specific, found to impose sent a strong message to states, such as Illinois, with a restrictions on first and early second trimester procedures history of anti-abortion legislation, that it will not tolerate must be strictly reviewed and enjoined unless justified by a government interference with a woman's decision to have an compelling governmental interest. Akron, 462 U.S. at 420- abortion, or her physician's medical discretion in 21 n.l. Accordingly, in Akron, this Court expressly effectuating that decision, under the guise of regulating declined the City of Akron's invitation to apply the rational general health and welfare. Thornburgh, 477 U.S. at 759. basis analysis to abortion regulations. 11 Further, defendants' own contention that they no longer Given the substantial burdens resulting from the scheme, apply these purported health regulations to all who provide and the absence of any compelling justification, the Court of early abortion services (see Juris. St. 9) undercuts their Appeals appropriately affirmed the preliminary injunction claimed concern for safety. As the Court of Appeals noted, ordered by the District Court. Not only is a rational basis "[t]he State's attempt to regulate experienced, and therefore standard "wholly incompatible with the existence of the safer, physicians, more heavily than the occasional abortion fundamental right recognized in Roe V. Wade," Akron, 462 provider thus appears to lack even a reasonable basis." U.S. 420-21 1. but the Court of Appeals indicated that this App. 24. 10 burdensome scheme lacked even a reasonable basis. App. 24. In light of the lower courts' findings that the challenged scheme was directed at abortions, defendants cannot obtain review by arguing that the challenged scheme is 11 The Supreme Court cases defendants cite (Juris. St. 26) do not "abortion-neutral" and therefore subject only to a rational support their argument that a rational basis standard is appropriate. In basis standard of review. (Juris. St. 25.) Moreover, none of those cases did the Court apply a rational basis standard. defendants' proposed rational basis analysis, which they Indeed, in Minneapolis Star & Tribune Co. V. Minn. Comm'r of claim is "supported by decisions of this Court in other Revenue, 460 U.S. 575 (1983), this Court strictly scrutinized a special contexts" (Juris. St. 26), has been expressly rejected by the tax on newspapers, even though there was no evidence of legislative Court in the abortion context. State regulations, whether intent to restrict newspapers. Nonetheless, the Court struck down the tax which, like the challenged scheme here, was found to impose a financial burden on the exercise of a fundamental right and which did not serve any compelling governmental interest. 10 Likewise, the attempt to justify the CON portion of the scheme as a cost-containment measure (Juris. St. 6) cannot provide a compelling None of defendants' cases refutes the well-established principle that interest because "the State has discontinued use of [the CON] method, when a general regulatory provision is applied in a manner that burdens [and] the State has never made such payments for abortions." App. 31. a fundamental right, it is unconstitutional. Compare Wisconsin V. Further, "[w]here the exercise of constitutional rights is concerned, the Yoder, 406 U.S. at 220 (neutral compulsory education law applied to government may play no role in determining whether outlets for their members of Amish religion unconstitutionally burdened their right to exercise are "needed." App. 31. the free exercise of religion). 18 19 In light of the threat of continued enforcement, the Court C. The Decision Below Is Consistent of Appeals properly rejected defendants' claim that their With This Court's Decisions In The alleged nonenforcement somehow rendered the controversy Areas Of Justiciable Controversies moot or nonjusticiable. App. 13-14. Regardless of the label And Severability. (Juris. St. 21-23), this Court has made clear, in cases relied upon by the Court of Appeals, App. 11, but disregarded by 1. In Light Of Defendants' defendants, that voluntary cessation of illegal conduct does Continuing Policy Of not deprive a lower federal court of jurisdiction to affirm a Enforcement, The Court Of preliminary injunction unless the wrongful conduct could not Appeals Appropriately Affirmed reasonably be expected to recur, City of Mesquite V. The Preliminary Injunction. Aladdin's Castle, Inc., 455 U.S. 283, 289 n. 10 (1982). and all harm caused by the illegal conduct has been "irrevocably Defendants' claim that the ruling below conflicts with eradicated." City of Los Angeles V. Lyons, 461 U.S. 95, Supreme Court decisions concerning justiciable 101 (1983) (citation omitted). Defendants could not meet controversies (Juris. St. 21-23) does not present an issue this standard here. Particularly considering Illinois' history within the ambit of 28 U.S.C. § 1254(2); the Court of of enacting restrictive abortion legislation and reenacting Appeals' ruling that the case was not moot does not such legislation after it previously has been stricken, see constitute a declaration that a state statute is invalid "as Charles V. Daley, 749 F.2d 452, 458 (7th Cir. 1984), appeal repugnant to the Constitution, treaties or laws of the United dism'd sub nom., Diamond V. Charles, 476 U.S. 54 States 28 U.S.C. § 1254(2). Further, defendants (1986), physicians "should not have to risk loss of their present no conflict that would warrant the exercise of professional licenses to explore the contours of the asserted certiorari jurisdiction. non-enforcement position." App. 14. Contrast Poe V. Ullman, 367 U.S. 497 (1961) (cited at Juris. St. 23) (no Without an injunction, Dr. Ragsdale would have been justiciable controversy because statute essentially not forced to close his practice, and plaintiff Margaret Moe enforced in 82 years). 12 would not have been able to offer abortion services to her patients. App. at 22. Defendants' employees are given "absolute prosecutorial discretion" as to when and how to 12 Defendants inappropriately rely on J.N.S. V. State of Indiana, 712 enforce statutory provisions (Juris. St. 10). Testimony by F.2d 303 (7th Cir. 1983). and C.I.O. V. McAdory, 325 U.S. 472 defendants' own enforcement personnel revealed that (1945). to argue that no justiciable controversy existed before the Count defendants have no consistent policy as to nonenforcement, of Appeals. In those cases, a constitutional violation would have occurred only had the challenged statutes been given a particular nor have they publicized in any consistent fashion their construction, and the courts in both cases found no threat of such a alleged nonenforcement policy. App. 10, 14. construction. See also Alabama State Federation of Labor V. McAdory. 325 U.S. 450 (1945), relied on in C.I.O., 325 U.S. 472. By contrast, (Footnote continued on the following page) 20 21 procedures. Compare Regan v. Time, Inc., 468 U.S. 641, Defendants' alternative argument, that the Eleventh 652 (1984). This narrow injunction, limiting application of Amendment barred the entry of portions of the preliminary the law as opposed to striking it entirely, is consistent with injunction, mischaracterizes this Court's decision in Green the Illinois General Assembly's expressed intention in the V. Mansour, 474 U.S. 64 (1985), and the Court of Appeals' ASTC Act. See III. Rev. Stat. ch. 111 1/2, § 157-8.15; decision in Watkins V. Blinzinger, 789 F.2d 474 (7th Cir. App. 165 (to the extent that the Act is held unconstitutional 1986), cert. denied, U.S. , 107 S. Ct. 1976 (1987). as applied to particular person(s). court appropriately can In those cases, the Eleventh Amendment was a barrier to sever by allowing the statute to remain enforceable as to all further federal litigation because a ruling by the federal court others). effectively would have resulted in financial consequences for the State because of past violations of federal law. No such The Court of Appeals correctly refused defendants' risks exists here, where plaintiffs have not sought damages invitation to rewrite the challenged legislation. App. 32-33. or economic relief from the State. Further, when the It held that the licensing provision, "an integral part' of the purpose of the federal court remedy is to require the state scheme as a whole," was itself unconstitutional as it applied officer to conform future conduct to the dictates of federal to plaintiffs. App. 32, see also App. 23-24. Without the law, it has long been established that the Eleventh licensing requirement, the remaining provisions, many of Amendment erects no barrier to suit. Ex Parte Young, 209 which themselves were unconstitutionally burdensome, U.S. 123 (1908). would not be applicable. Thus, the Court of Appeals held that it could not "untangle the constitutional from the 2. The Court Of Appeals Properly unconstitutional provisions App. 33 (quoting Enjoined The Entire Regulatory Mahoning, 610 F.2d at 460), without impermissibly Scheme As It Applies To Early usurping the Illinois General Assembly's legislative Abortion Services. function. App. 33. Cognizant of the policies underlying the severability This is consistent with defendants' own cases. Severing doctrine, both the District Court and the Court of Appeals specific provisions is not appropriate "if what is left is [not] tailored the injunction to apply only to the extent required to fully operative as a law,'' or if ""it is evident that the protect plaintiffs' constitutional rights, thereby leaving the Legislature would not have enacted those provisions which State free to apply the regulatory scheme to all non-abortion are within its power, independently of that which is not.'" Buckley V. Valeo, 424 U.S. 1, 108-09 (1976) (per curiam) (Continued) (quoting Champlin Refining Co. V. Corporation in the present case, the State defends unconstitutional laws by claiming Commission, 286 U.S. 210, 234 [1932]); see also Juris. they will not enforce the express terms of the statutes as they were St. 29. Here, neither condition is met. enacted by the Legislature. 22 CONCLUSION For all of the foregoing reasons, this appeal should be dismissed, or in the alternative, the judgment below should be affirmed. Respectfully submitted, ALAN S. GILBERT COLLEEN K. CONNELL LORIE A. CHAITEN (COUNSEL OF RECORD) SONNENSCHEIN CARLIN ROGER BALDWIN NATH & ROSENTHAL FOUNDATION OF 8000 Sears Tower AMERICAN CIVIL Chicago, Illinois 60606 LIBERTIES UNION OF (312) 876-8000 ILLINOIS 20 E. Jackson Boulevard Suite 1600 Chicago, Illinois 60604 (312) 427-7330 Dated: January 14, 1989 No. 88- 790 IN THE Supreme Court of the United tates OCTOBER TERM, 1988 BERNARD J. TURNOCK, M.D., M.P.II., Director of the Illinois Department of Public Health, et al., Appellants, RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From The United States Court Of Appeals For The Seventh Circuit APPELLANTS' REPLY TO MOTION TO DISMISS OR AFFIRM NEIL F. HARTIGAN Attorney General, State of Ulinois ROBERT J. RUIZ Solicitor General, State of Illinois 100 West Randolph Street, 12th Floor Chicago, Illinois 60601 (312) 917 3000 Attorneys for Appellants MICHAEL J. HAYES* KATHLEEN KREISEL FLAHAVEN ROGER P. FLAHAVEN Grapys STEVENS Assistant Attorneys General 100 West Randolph Street, Buth Floor Chicago, Illinois 60601 (312) 917 3654 of Counsel * Counsel of Revord Printed by Antionity of the State of Dhing d'o 316.00 " 12,80 i TABLE OF CONTENTS PAGE TABLE OF CONTENTS i TABLE OF AUTHORITIES ii THIS COURT HAS APPELLATE JURISDIC- TION TO REVIEW THE JUIGMENT OF THE COURT OF APPEALS PURSUANT TO 28 U.S.C. SECTION 1254(2) 1 THE QUESTIONS PRESENTED ARE SUB- STANTIAL 4 A. THE COURT OF APPEALS ERRONEOUS- LY FOUND THAT THE CHALLENGED STATUTES AND REGULATIONS ARE UNCONSTITUTIONAL 4 B. THE MAJORITY OPINION CONFLICTS WITH DECISIONS OF THIS AND OTHER COURTS REGARDING SEVERANCE OF PURPORTEDLY UNCONSTITUTIONAL PROVISIONS 8 C. THE COURT OF APPEALS ERRONEOUS I.Y ASSUMED JURISDICTION OVER UN. ENFORCED PROVISIONS 9 CONCLUSION 10 ii iii TABLE OF AUTHORITIES Statutes 28 U.S.C. Section 1254(2) 1, 2, 3, 4 Cases PAGE(S) Ambulatory Surgical Treatment Center Act, III. Rev. Stat. ch. 111½, pars. 157-8.1 et seq. Baird v. Department of Public Health, 599 F.241 passim 1098 (1st Cir. 1979) 6 Health Facilities Planning Act, Birth Control Centers, Inc. v. Reizen, 743 F.2d 352 111. Rev. Stat. ch. 111½, pars. 1151 et seq. .. passim (6th Cir. 1984) 5, 7, 8 Medical Practice Act, City of Akron V. Akron Center for Reproductive III. Rev. Stat. ch. 111, par. 4400-22 ...... passim Health, Inc., 462 U.S. 416 (1983) 5, 6 Ex Parte Young, 209 U.S. 123 (1908) 10 Regulations Fox Valley Reproductive Health Care Center, Inc. Ambulatory Surgical Treatment Center Licensing v. Arft, 446 F.Supp. 1072 (E.D. Wis. 1978) 6 Requirements, 77 III. Adm. Code, Ch. 1, Sec- Friendship Medical Center, Ltd. v. Chicago Board tion 205, Subchapter 6 passim of Health, 505 F.2d 1141 (7th Cir. 1974), cert. denied, 420 U.S. 997 (1975) 6 Hodgson v. Lawson, 542 F.2d 1350 (8th Cir. 1976) 6 Mahoning Women's Center v. Hunter, 610 F.2d 456 (6th Cir. 1979), vacated on other grounds, mem., 447 U.S. 918 (1980) 5 Thornburgh v. American College of Obstetricians and Gynecologists, 476 U.S. 747 (1986) 3, 5 Constitutional Provisions U.S. Const. Amend. XI 9, 10 No. 88-790 IN THE Supreme Court of the United States OCTOBER TERM, 1988 BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illinois Department of Public Health, et al., Appellants, V. RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From The United States Court Of Appeals For The Seventh Circuit APPELLANTS' REPLY TO MOTION TO DISMISS OR AFFIRM THIS COURT HAS APPELLATE JURISDICTION TO REVIEW THE JUDGMENT OF THE COURT OF APPEALS PURSUANT TO 28 U.S.C. SECTION 1254(2) In their Jurisdictional Statement (pp. I-2), defendants demonstrated that this Court has appellate jurisdiction to review the final judgment entered by the Court of Ap- peals. That judgment held unconstitutional the challenged -2- -3- provisions of the Illinois Medical Practice Act (MPA), the MR. GILBERT: One other matter, and this doesn't Illinois Ambulatory Surgical Treatment Center Act (ASTC) relate directly to this order, and that is, just in terms and related regulations, and the Illinois Health Facilities of the future course of this proceeding, given the Planning Act (HFPA) to the extent any person or facil- scope of the evidentiary hearing and the briefing that has gone on and the scope of your Honor's order, ity offers or performs, or desires to offer or perform first it seems to us that there probably isn't a need to and early second trimester abortions or abortion-related have another trial in this matter and that we have gynecological procedures. pretty much aired the issues here and relatively com- pletely and, to that end, we have made a suggestion The plaintiffs attempt to argue that this matter is not to the state, a request, that we would be willing to subject to review under 28 U.S.C. Section 1254(2). In SO turn this into a final injunction order pursuant to arguing, the plaintiffs incorrectly focus upon the district Rule 65, which allows a proceeding for preliminary court preliminary injunction order, rather than the deci- injunction to be a proceeding for a final and perma- sion of the Court of Appeals. (Pls.' Motion, pp. 5-7). In nent injunction as well. (Tr. 861-62). addition to affirming the preliminary injunction, the Court In the same vein, the district court judge and plaintiffs' of Appeals invalidated the licensure requirement and counsel stated as follows: struck the other challenged provisions as applied to first THE COURT: . I can't really think of anything and early second trimester abortions. more that either side would put in that would really In discussing the severability issues presented by the make all that much difference in the Seventh Circuit's case, moreover, the plaintiffs acknowledge that the Court decision in the case. It is really-the guts of the argu- ment on both sides are in and the evidence is in. It of Appeals has held that the Illinois general "licensing is really a question of interpreting the Supreme Court provision was itself unconstitutional as it applied to decisions and maybe drawing a few reasonable infer- plaintiffs." (Pls.' Motion, p. 21; App. 25). Similarly, the ences. But there really isn't all that much in the way Court of Appeals need not have considered the severabil- of factual disputes, it is really more a question of in- ity issues unless the statutes and regulations had been terpretation of the existing laws. (Tr. 864-65). held unconstitutional. In light of the holding by the Court MR. GILBERT: Yes. Right. That's how we see it. of Appeals, this Court has appellate jurisdiction under 28 (Tr. 865). U.S.C. Section 1254(2). In Thornburgh v. American College of Obstetricians and In addition, the plaintiffs misstate that they and the dis- Gynecologists, 476 U.S. 747 (1986), this Court concluded trict court contemplated further evidentiary hearings after that it had no appellate jurisdiction under Section 1254(2). the preliminary injunction trial. (Pls.' Motion, P. 6). That 476 U.S. at 755. This Court reached that conclusion be- statement is contradicted by the comments of plaintiffs' cause the Third Circuit had not held the entire Act un- counsel and the district court judge subsequent to the is- constitutional, had invalidated only some provisions, and suance of the preliminary injunction decision. At that time, had remanded the case for further development of the plaintiffs' counsel volunteered the following statements: facts. 476 U.S. at 754-55. -4- -5- In this case, however, the Seventh Circuit did hold the The plaintiffs suggest that this case is unimportant and challenged acts unconstitutional, thereby invalidating all attempt to argue that the decision of the Court of Ap- of the regulatory provisions as applied to first and early peals "replicates" this Court's decisions in City of Akron second trimester abortions. The Seventh Circuit did not U. Akron Center for Reproductive Health, Inc., 462 U.S. remand for further development of the facts. Clearly, the 416 (1983) and Thornburgh 11. American Coflege of Ob- Seventh Circuit judgment is final and this Court has ap- stetricians and Gynecologists, 476 U.S. 747 (1986). (Pls.' pellate jurisdiction under 28 U.S.C. Section 1254(2). Motion, P. 8). That argument is incorrect. At issue in this case is the State's authority to license and regulate outpatient surgical facilities in which abor- THE QUESTIONS PRESENTED tions are performed to the same extent it licenses and ARE SUBSTANTIAL regulates outpatient surgical facilities in which other surgical procedures are performed. Neither Akron nor Thornburgh involved such generally applicable statutes and regulations. Both of those cases addressed challenges A. to abortion-specific statutes. THE COURT OF APPEALS ERRONEOUSLY FOUND THAT THE CHALLENGED STATUTES AND REGULA- In fact, none of the cases relied upon by the plaintiffs TIONS ARE UNCONSTITUTIONAL support the Court of Appeals' decision to exempt out- In enacting the ASTC Act, Illinois recognized the in- patient surgical facilities in which abortions are performed from a general licensure provision. For example, plain- creasing trend toward the development of free-standing tiffs cite Birth Control Centers, Inc. v. Reizen, 743 F.2d or outpatient surgical facilities. Abortions are performed 352 (6th Cir. 1984). In that case, however, the Sixth Cir- in 22 of the 42 outpatient surgical facilities which are cuit did not invalidate on privacy grounds the State's au- licensed in Illinois. The decision of the Court of Appeals has exempted those 22 surgical facilities from licensure thority to license outpatient surgical facilities in which abortions are performed. In fact, the licensure question and regulation to the extent they perform first and early second trimester abortions. was not perceived to involve privacy rights and was dealt with as an equal protection issue. More importantly, the This exemption has undermined Illinois' duty and au- court upheld the requirement as reasonable. 743 F.2d at thority to protect patients who are undergoing abortions 358-59. at such facilities in the same manner that the state can Plaintiffs also rely upon Mahoning Women's Center D. protect patients who are undergoing other surgical pro- Hunter, 610 F.2d 456 (6th Cir. 1979), vacated on other cedures. This exemption is inconsistent with decisions of grounds, mem., 447 U.S. 918 (1980). In that case, the other circuits and, contrary to the plaintiffs' suggestions, Sixth Circuit invalidated in its entirety an ordinance which is not supported by decisions of this Court. singled out for extensive regulation only medical clinics -6- -7- performing abortions. Similarly, plaintiffs cite the decisions in this case. In the Jurisdictional Statement, defendants in Friendship Medical Center, Ltd. v. Chicago Board of demonstrated the legitimate and substantial purposes of Health, 505 F.2d 1141 (7th Cir. 1974), cert. denied, 420 the challenged statutes (Juris. St., PP. 5-6 and 25) and U.S. 997 (1975) and Fox Valley Reproductive Health Care regulations (Juris. St., PP. 11-14). Center, Inc. v. Arft, 446 F.Supp. 1072 (E.D. Wis. 1978). In addition, the plaintiffs suggest that it is not reason- Again, these cases dealt with abortion-specific ordinances, able for the State to regulate surgical facilities in which rather than generally applicable licensure provisions. Thus, abortions are performed more heavily than doctor's offices these cases do not support the decision of the Seventh in which abortions are performed. (Pls.' Motion, P. 16). Circuit to exempt from general licensure provisions out- The Sixth Circuit dealt with a similar argument in Birth patient surgical facilities in which first and early second Control Centers, Inc. P. Reizen, 743 F.2d 352 (6th Cir. trimester abortions are performed. 1984). The court recognized that in private offices the Contrary to plaintiffs' assertion, City of Akron v. Akron physician generally has direct control over staff and of Center for Reproductive Health, Inc., 462 U.S. 416, 420 fice functions, while in outpatient surgical facilities non- n.1 does not hold that abortion-neutral statutes and regu- physicians may have control over personnel, equipment lations "must be strictly reviewed and enjoined unless and the design of the facility. The Sixth Circuit concluded, justified by a compelling government interest." (Pls.' Mo- therefore, that it was not unreasonable for Michigan to tion, pp. 16-17). Akron involved a challenge to an ordi- decide to regulate free-standing surgical facilities includ- nance enacted "to regulate the performance of abortions" ing abortion clinics while not regulating physicians' offices. (id. at 419), rather than abortion-neutral provisions. Defen- 743 F.2d at 358-59. The statutes and regulations which dants maintain that the rational basis test should have were invalidated in this case reflect a similar reasonable been applied to the abortion-neutral provisions at issue decision by the State of Illinois. in this case. (Juris. St., pp. 25-26). The State has the duty and the power to protect the Plaintiffs' attempts to distinguish Baird v. Department health, safety and welfare of its citizens by licensing and of Public Health, 599 F.2d 1098 (1st Cir. 1979) and Hodg- regulating outpatient surgical facilities. The State's im- son v. Lawson, 542 F.2d 1350 (8th Cir. 1976) also miss portant interests in assuring that certain minimal stan- the mark. Those cases uphold licensing standards of out- dards be complied with at such facilities do not cease to patient surgical facilities in which pregnancy terminations exist when abortions are performed at such facilities.' In are performed. Thus, those decisions conflict with the rul- ing of the Seventh Circuit in this case which held that 1 The American College of Obstetricians and Gynecologists' Stan- licensing of such facilities constitutes an unconstitutional dards for Obstetric-Gynecologie Services, Sixth Edition [ACOG invasion of privacy. Standards provides that "|A|mbulatory care facilities for abortion services should meet the same standards of care as for other sur- Plaintiffs state that defendants failed to offer any justifi- gical procedures." (ACOG Standards 62). The Standards further cation to support the challenged statutes and regulations. provide that "Ambulatory surgical facilities that are freestanding or hospital-based should maintain the same surgical, anesthetic, (Pls.' Motion, p. 12). That statement ignores the record and personnel standards that hospitals do." (ACOG Standards 61). -8- -9- fact, the plaintiffs' trial experts testified that medical were individually analyzed. The same procedure should education in this country has paid little attention to abor- have been utilized by the Seventh Circuit in this case. tion services and that there are few surgical procedures given SO little attention and SO underrated in its poten- C. tial hazard as abortion. THE COURT OF APPEALS ERRONEOUSLY ASSUMED JURISDICTION OVER UNENFORCED PROVISIONS. B. In the Jurisdictional Statement, defendants demonstrated THE MAJORITY OPINION CONFLICTS WITH DECI- that the Seventh Circuit's assumption of jurisdiction over SIONS OF THIS AND OTHER COURTS REGARDING unenforced provisions conflicts with decisions of this Court SEVERANCE OF PURPORTEDLY UNCONSTITUTIONAL and Courts of Appeals regarding justiciability standards PROVISIONS. as well as with decisions addressing the jurisdictional bar In the Jurisdictional Statement, defendants demonstrated created by the Eleventh Amendment. Claris. St., PP. 21- that the majority opinion of the Seventh Circuit erred in 23). The plaintiffs, however, attempt to posit the case as rejecting the argument that any purportedly unconstitu- one involving mootness issues. (Pls.' Motion, P. 19). tional provisions be severed. (Juris. St., pp. 28-29). Plain- The uncontradicted evidence of record established that tiffs ignore the thrust of defendants' argument. (Pls.' Mo- due to various court decisions, well prior to the com- tion, pp. 20-21). In this case, the lower courts and plain- mencement of this action, the State ceased to enforce cer- tiffs argue that the appropriate analysis entails the estima- tion of the cost of compliance with all of the challenged tain challenged provisions: the abortion-specifie language regulations. (App. 22). This aggregated sum supposedly of par. 157-8.3 of the ASTC Act (App. 149-50); Sections substantiates the "impact on the abortion decision." Id. 205.740 (App. 222) (prohibition of second trimester abor- The nature and degree of the alleged burden on consti- tions in ASTCs) and 205.760 (App. 223) (abortion-specific tutional rights should not depend upon the number or reporting requirement) of the ASTC Regulations; and par. volume of statutes and regulations which are challenged. 4400-22 of the MPA. (App. 193). Rather, those statutes and regulations should be seruti- While the plaintiffs now suggest that there is a "threat nized independently and on their own merit. of continued enforcement" of those provisions, they do not Birth Control Center, Inc. v. Reizen, 743 F.2d 352 (6th specify what future conduct State officials must change to conform to the dictates of federal law. (Pls.' Motion, Cir. 1984) offers further support for the defendants' argu- ment that the Seventh Circuit improperly invalidated all PP. 18-20). Even the Seventh Circuit noted that State of of the challenged provisions. In Reizen, the Sixth Circuit ficials cannot be required to remove or amend regulations upheld the licensure requirement, upheld certain regula- which are not being enforced. (App. 13). tions and struck other regulations. That court did not re- Defendants maintain that no justiciable controversy fuse to sever those provisions which it found unconstitu- existed at the time of the filing of this case with respect tional. Rather, the challenged statutes and regulations to those challenged provisions which were no longer being -10- enforced. Further, the exception to the Eleventh Amend- ment's jurisdictional bar relied upon by the plaintiffs (Pls.' Motion, p. 20) is inapplicable to the challenge to the un- enforced provisions. Absent some ongoing violation of federal law, Ex Parte Young, 209 U.S. 123 (1908) does not apply and the jurisdictional barrier created by the Eleventh Amendment remains intact. CONCLUSION For these reasons, this Court should deny plaintiffs' Motion to Dismiss or Affirm and should note probable jurisdiction of this appeal. Respectfully submitted, NEIL F. HARTIGAN Attorney General, State of Illinois ROBERT J. RUIZ Solicitor General, State of Illinois 100 West Randolph Street, 12th Floor Chicago, Illinois 60601 (312) 917-3000 Attorneys for Appellants MICHAEL J. HAYES * KATHLEEN KREISEL FLAHAVEN ROCER P. FLAHAVEN GLADYS STEVENS Assistant Attorneys General 100 West Randolph Street, 13th Floor Chicago, Illinois 60601 (312) 917-3654 Of Counsel * Counsel of Record January 27, 1989 8 85.7 90 IN THE Supreme Court of the United States OCTOBER TERM, 1988 BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illinois Department of Public Health, et al., Appellants, V. RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From The United States Court Of Appeals For The Seventh Circuit APPENDIX TO JURISDICTIONAL STATEMENT NEIL F. HARTIGAN Attorney General, State of Illinois ROBERT J. RUIZ Solicitor General, State of Illinois 100 West Randolph Street, 12th Floor Chicago, Illinois 60601 (312) 917-3000 Attorneys for Appellants MICHAEL J. HAYES* KATHLEEN KREISEL FLAHAVEN ROGER P. FLAHAVEN GLADYS STEVENS Assistant Attorneys General 100 West Randolph Street, 13th Floor Chicago, Illinois 60601 (312) 917-3654 Of Counsel * Counsel of Record Printed by Authority of the State of Illinois (P.O. 34259-60-11-10-88) i INDEX TO APPENDIX PAGE A-Slip Opinion of the United States Court of Appeals for the Seventh Circuit, March 10, 1988 1 B- Judgment of the United States Court of Ap- peals for the Seventh Circuit, March 10, 1988 102 C- Order of the United States Court of Appeals for the Seventh Circuit Amending the Slip Opinion, April 13, 1988 103 D- Amended Order of the United States Court of Appeals for the Seventh Circuit Denying the Petition for Rehearing and Suggestion for Re- hearing En Banc, August 16, 1988 105 E- Order of the United States Court of Appeals for the Seventh Circuit Denying the Petition for Rehearing and Suggestion for Rehearing En Banc, August 12, 1988 107 F- Class Certification and Preliminary Injunction Order of the United States District Court for the Northern District of Illinois, Eastern Divi- sion, December 11, 1985 109 G- Memorandum Opinion and Order of the United States District Court for the Northern District of Illinois, Easte, Division, November 27, 1985 112 H-Notice of Appeal, November 7, 1988 146 ii I- Ambulatory Surgical Treatment Center Act, 111½ III. Rev. Stat. " 157-8.1, et seq. 149 J- Health Facilities Planning Act, 111½ III. Rev. Stat. 11 1151, et seq. 166 IN THE K- Medical Practice Act, 111 III. Rev. Stat. 1 4400- 22 193 Supreme Court of the United States L- 77 Illinois Administrative Code, Chapter 1, § 205, Subchapter b 203 OCTOBER TERM, 1988 BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illinois Department of Public Health, et al., Appellants, V. RICHARD M. RAGSDALE, M.D., et al., Appellees. On Appeal From The United States Court Of Appeals For The Seventh Circuit APPENDIX TO JURISDICTIONAL STATEMENT App. 1 APPENDIX A IN THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT No. 85-3242 RICHARD M. RAGSDALE, et al., Plaintiffs-Appellees, v. BERNARD J. TURNOCK, Director of the Illinois Department of Public Health, et al., Defendants-Appellants. Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 85-C-6011-John A. Nordberg, Judge. ARGUED OCTOBER 22, 1986-DECIDED MARCH 10, 1988 Before BAUER, Chief Judge, COFFEY, Circuit Judge, and ESCHBACH, Senior Circuit Judge. ESCHBACH, Senior Circuit Judge. Plaintiffs consist of a class of all duly licensed physicians and surgeons per- forming or who desire to perform pregnancy terminations in Illinois and a class of all women in the State of Illinois of child-bearing age who desire or may desire an abortion at sometime in the future. Defendants are a class of the State's Attorneys of all of the counties of the State of Illinois,¹ the Director of the Illinois Department of Public I Class certification as to both the defendant and plaintiff classes was challenged below. The district court granted certification. 625 F. Supp. at 1219-24. That ruling is not challenged on appeal. App. 3 App. 2 bulatory Surgical Treatment Center Act, 111½ Ill. Rev. Health, the Illinois Attorney General, and the Director Stat. 11 157-8.1, et seq. (the "ASTCA" or the "Act"), pro- of the Illinois Department of Registration and Education. vides for the licensure of all ASTCs, which it defines as Plaintiffs sued under 42 U.S.C. § 1983 and 28 U.S.C. "any place devoted primarily to the per- §§ 2201-02, seeking declaratory and injunctive relief to the formance of surgical procedures or any facility in which effect that three Illinois statutes and the regulations there- a medical or surgical procedure is utilized to terminate under violate the constitutional right to privacy, specifical- a pregnancy, irrespective of whether the facility is de- ly to abortion, as established in Roe v. Wade, 410 U.S. voted primarily to this purpose 111½ Ill. Rev. Stat. 113, 93 S. Ct. 705 (1973), and subsequent Supreme Court 9 157-8.3(A). In addition, plaintiffs have challenged those cases. This case comes to us on appeal from the district sections of the Health Facilities Providers Act, 111½ III. court's grant of plaintiffs' motion for a preliminary injune- Rev. Stat. 11 1151, et seq. ("HFPA"), which require any- tion. 625 F. Supp. 1212 (N.D. Ill. 1985). Because we be- one seeking to open an ASTC to obtain a certificate of lieve certain of the claims are moot, we vacate in part. need for the facility from the Department of Public Health In most respects, however, we affirm the preliminary in- after a public hearing and 120-day review period. See junction. 111½ Ill. Rev. Stat. 11 1155-1160.³ I 2 continued (b) [a licensed hospital]; A. Statutory and Regulatory Provisions (c) an ambulatory surgical treatment center or hospi- The statutory and regulatory scheme is somewhat com- talization or care facility maintained by the State or any plex. Therefore, we set it out in some detail. Section 16(1) agency thereof of the Medical Practice Act ("the MPA"), 111 Ill. Rev. (d) ambulatory surgical treatment centers, hospitaliza- Stat. 9 4433(1), allows for revocation or suspension of the tion or care facilities maintained by the Federal Govern- license of any physician who performs an "elective abor- ment, or tion" in any place other than a licensed Ambulatory Sur- (e) ambulatory surgical treatment centers, hospitaliza- gical Treatment Center ("ASTC"), a hospital, or a facil- tion or care facilities maintained by any university or col- lege established under the laws of this State and supported ity run by the state or federal governments.2 The Am- principally by public funds raised by taxation. 3 Section 1158 of the Health Facilities Planning Act reads, in per- 2 Section 16(1) of the Medical Practice Act reads, in pertinent tinent part: part: When an application for a permit is initially reviewed by The Department may revoke, suspend, place on probationary a recognized areawide health planning organization or [the status, or take any other disciplinary action as the Depart- Department of Public Health] [they] shall afford an op- ment may deem proper with regard to the license of any portunity for a public hearing within a reasonable time after person in this state to practice medicine receipt of the complete application. Such hearing shall be upon any of the following grounds: conducted in the area or community where the proposed proj- ect is to occur, and shall be for the purpose of allowing the (1) Performance of an elective abortion in any place applicant and any interested person to present public testi- other than: mony concerning the approval, denial, renewal or revocation (a) a facility licensed pursuant to the "Ambulatory Sur- of the permit. The State Board shall promulgate reason- gical Treatment Center Act" able rules and regulations governing the procedure and con- (Footnote continued on following page) duct of such hearings. App. 4 App. 5 The bulk of plaintiffs' specific challenges, however, are tion 157-8.12. Section 157-8.12 provides for a fine of directed at the ASTCA and the regulations promulgated $10,000 per day for operating a facility without a license thereunder, and their application, via the MPA, to phy- or otherwise violating the Act. Section 157-8.13 makes the sicians desiring to perform first and early second trimester operation of a facility in violation of the Act or regula- abortions. Accordingly, we set forth the ASTCA and its tions a public nuisance subject to injunction. accompanying regulations in some detail.⁴ Section 157-8.15 provides, in broad terms, for severabil- The Act itself is largely procedural in operation and ity of the provisions of the Act. grants the Department of Public Health the authority to promulgate specific regulations governing ASTCs. 111½ The general regulations under the ASTCA, found in Ill. Rev. Stat. 1 157-8.10. However, certain specific provi- Title 77 of the Illinois Administrative Code, are detailed sions of the statute also prescribe requirements for ASTCs. and govern many aspects of an ASTC. Section 6.1 of the ASTCA requires any corporation oper- For example, there are quite specific physical plant reg. ating an ASTC devoted primarily to providing facilities ulations which require: (1) a minimum size of 250 sq. ft. for abortion to have on its board of directors a physician or at least one procedure room (any additional ones must who is licensed to practice medicine in all of its branches be no smaller than 120 sq. ft.) and a minimum of 80 sq. and is actively engaged in the practice of medicine at the ft. for examinations rooms; (2) that an ASTC be "iden- ASTC. Sections 157-8.5 and 8.6 generally provide for li- tifiably separate from other medical facilities and func- censing with an initial fee of $500 and an annual renewal tions"; (3) that a "control station" be located to allow fee of $300. Additionally, those sections require that a visual surveillance of traffic entering the operating suite; licensed facility be under the supervision of one or more (4) that facilities including a lounge, lockers, separate toilets, physicians and that at least one physician have admitting and a space for changing clothes be provided for male and and surgical privileges at an Illinois hospital. Sections female personnel; (5) a separate janitorial closet for the 157-8.7a and 8.7b require statements regarding the owner- surgical suite; (6) a "diagnostic facility" if pre-admission ship of and financial condition of the facility. Section evaluation tests are to be performed; and (7) minimum 157-8.8 requires Department approval of construction of, corridor (5' or 8' depending on whether stretchers are to alterations of, or additions to a facility. Section 157-8.9 be used) and door (3' or 3'8") widths. § 205.1310-1390. provides for quarterly inspections of facilities and provides Also, an elaborate air-conditioning, heating, and ventila- for confidentiality of information received by the Depart- tion system to provide for specific filter efficiencies and ment. airflow relationships between rooms is required. § 205.1540 and Table A. The remedial sections of the Act provide an array of enforcement mechanisms. Section 157-8.9a provides that The licensure regulation provides for a detailed appli- a facility may be closed by administrative order if its con- cation including identification of the owners and operators tinued operation constitutes an imminent and serious men- of the facility, its location, a description and architectural ace to the health or safety of the patients or if the plans, documentation of compliance with building and safe- operator thereof has been convicted of a violation of sec- ty codes, a description of the services to be performed, and a list of all personnel and their qualifications. A new application is required for a change in ownership, loca- 4 Selected regulations that are discussed in detail in our analysis tion of the facility, remodeling, or addition of services or infra in the text are set forth in an Appendix to this opinion. programs. Notice to the Department must be given of any App. 6 App. 7 change in the administrative staff, medical director, staff be maintained with the patient's clinical records. $ 205.520. physicians, supervising nurse, addition or deletion of sur- All removed tissues are to be examined by a consulting gical procedures, or change in any shareholder interest pathologist. $ 205.530. of five percent or more. § 205.120. Post-operative care regulations provide that any patient Other general requirements include an organizational plan who has had general anesthesia, local anesthesia with seda- which is available for public information, a policies and tion, or pregnancy termination is required to be observed procedures manual, and written personnel policies including for a period of time sufficient to detect any immediate job descriptions. § 205.310. All facilities are required to post-operative complications, and that no patient be re- have the following personnel present during the operative quired to leave in less than one hour. $ 205.540. Addi- and post-operative period for all patients: a physician, a tionally, written documentation is required of a transfer registered professional nurse with post-graduate educa- agreement with a licensed hospital within fifteen minutes tion or experience in surgical nursing, and a person cer- of the facility, or that the medical director of the ASTC tified in "Basic Life Support" by the American Heart (or each staff physician of the ASTC) has admitting priv- Association. Sections 205.320-40. Additionally, each facil- ileges at such a hospital. § 205.540. ity must have either a certified medical technician or a Detailed clinical records are also required to be main- written agreement with a licensed laboratory to perform tained. § 205.610. Additionally, facilities are required to required laboratory procedures. § 205.350. A consulting make annual statistical reports that include the number committee must be established to develop standards of and type of procedures performed, the number and type professional work and a physician must serve as the med- of complications reported, the number of patients requir- ical director of the facility. § 250.230. ing transfer to a hospital due to complications, the number With regard to equipment, all facilities are required to of patients returning for follow-up, and the number of have monitoring equipment, suction apparatus, oxygen, deaths. and cardiac pulmonary resuscitation equipment. § 205.410. The regulations also have an abortion-specific subpart Additional written procedures are required to govern care, which requires: (1) at least one registered professional use, sterilization, storage and disposal of all materials, and nurse with post-graduate education or experience in ob- to govern storage and use of all medications. Id. Addi- stetrical or gynecological nursing, section 205.720; (2) test- tional written procedures are required for garbage and ing and reporting of the results to the patient of blood refuse removal, insect and rodent control, and mainte- Rh factor and diagnosis of pregnancy, section 205.730(a); nance of heating, ventilation and utility service. § 205.420. and (3) counseling by someone specifically trained to give Patient care regulations include a requirement of a writ- it and who has no financial interest in the patient's deci- ten "emergency" procedure in case of fire, explosion, or sion, which counseling must include a discussion of alter- "other non-patient medical emergency," and preparation natives, description of the procedure to be performed, and to manage the emergencies normally associated with the an explanation of risks and possible complications, section surgical procedures performed. § 205.510. A "complete 205.730(b). Contraceptive information may be provided physical" is required and specified tests are required to post-operatively, and shall be provided if desired by the be performed by a qualified laboratory technician for any patient. Id. Counseling must take place in a room separate procedures performed under general anesthesia, local an- from the procedure room, and a record of the counseling esthesia with sedation, or any pregnancy termination. A given is to be included in the patient's clinical record. Id. signed, written informed consent for any procedure is to App. 8 App. 9 The subpart contains its own reporting requirement which Ct. 2532 (1983). An internal memorandum of the Depart- requires monthly reporting of each procedure "on forms ment of Public Health following the decisions in those provided by [the Department]." Additionally, the regula- cases opined that they confirmed the unconstitutionality tions prohibit an ASTC from performing abortions on pa- of the second trimester hospitalization requirement in the tients with a gestational age exceeding twelve weeks. Illinois statutes and regulations. See Deft. Ex. 4. Repre- § 205.740. sentatives of the defendants testified at trial that the re- quirement is not currently being enforced for this reason. B. Enforcement Policies Defendants also contend that section 10 of the Illinois Not all of the provisions of challenged statutes and reg- Abortion Law of 1975, an abortion-specific reporting re- ulations are being enforced. Since 1981, the Act and regu- quirement, was enjoined by Judge Kocoras in Charles v. lations have been applied only to facilities which are pri- Carey, 579 F. Supp. 464 (N.D. Ill. 1983), aff'd in part, marily devoted to the performance of surgical procedures rev'd in part on other grounds Charles v. Daley, 749 F.2d (including abortions). This enforcement policy was adopted 452 (7th Cir. 1984) (Charles II), appeal dismissed sub in response to Village of Oak Lawn v. Marcowitz, 86 III. nom. Diamond v. Charles, 106 S. Ct. 1697 (1986), and that 2d 406, 427 N.E.2d 36 (1981), which refused to enforce, the abortion-specific reporting requirement in the ASTC in a criminal proceeding, that portion of a local ordinance regulations has not been enforced since that time. which incorporated the ASTCA definition of an ASTC These non-enforcement policies are not publicly stated, which covered "any facility where a medical or surgical but persons who inquire of the various enforcement agen- procedure is performed for the termination of pregnancy, cies are informed of them. regardless of whether the facility is primarily devoted to that purpose." The defendants also contend that the MPA's C. Individual Plaintiff Dr. Ragsdale revocation or suspension sanction for performing abortions outside an ASTC is similarly not being enforced, but the The individual plaintiff physician was required to relo- evidence on this point is equivocal. cate his practice, the Northern Illinois Women's Center ("the NIWC"), which is the only facility of its kind (that The defendants also contend that the prohibition on per- is, a non-hospital clinic) offering abortion services in a formance of second trimester abortions in ASTCs is not large area of northwestern Illinois because his landlord being enforced because it was considered enjoined by the refused to renew his lease. The facility which he had been order in Paula Poe v. IDPH, No. 78-C-4126 (N.D. III. operating was not in full compliance with the ASTCA reg- 1982). In that case, enforcement of section 4 of the Illinois ulations, but was nonetheless licensed as "substantially Abortion Law of 1975, 38 Ill. Rev. Stat. § 81-24, which complying" with them. When he sought another location, required all second trimester abortions to be performed he had to go through the certificate-of-need proceedings. in a hospital, along with "any related regulation" was en- The required public hearing on the application degenerated joined pending decision of three Supreme Court cases in- into a shouting match between "pro-choice" and "pro-life" volving a second trimester hospitalization requirement. members of the public, after which the doctor's prospec- Akron v. Akron Center for Reproductive Health, Inc., 462 tive landlord withdrew his lease commitment. In addition, U.S. 416, 103 S. Ct. 2481 (1983); Planned Parenthood As- officials charged with enforcing the regulations told him sociation, Inc. v. Ashcroft, 462 U.S. 476, 103 S. Ct. 2517 that they would require "considerably more substantial (1983); and Simopoulos v. Virginia, 462 U.S. 506, 103 S. compliance" than had been the case with his prior facili- App. 10 App. 11 ty, particularly with respect to the architectural require- moot a controversy and prevent its adjudication by a fed- ments. The cost of either building a facility or renovating eral court. City of Mesquite v. Aladdin's Castle, Inc., 455 one to comply with the regulations was estimated by the U.S. 283, 289 & n.10, 102 S. Ct. 1070, 1074 & 10 (1982); plaintiff at between $25.21 and $47.66 per patient. Because County of Los Angeles v. Davis, 440 U.S. 625, 631, 99 of his inability to find a location that can be renovated S. Ct. 1379, 1383 (1979); United States v. W.T. Grant Co., to comply with the ASTCA, particularly the structural 345 U.S. 629, 632-33, 73 S. Ct. 894, 897 (1953); see also and physical plant requirements of the regulations, at a Charles v. Daley, 749 F.2d 452, 456-58 (7th Cir. 1984) reasonable cost, Dr. Ragsdale will close the NIWC unless (Charles II), appeal dismissed sub nom., Diamond v. the statute is enjoined. Charles, 106 S. Ct. 1697 (1986). However, such cessation does render a controversy moot where there is no reason- D. Individual Plaintiff Margaret Moe able expectation that the putatively illegal conduct will Margaret Moe is a registered nurse who currently op- be repeated, and there are no remaining effects of the erates two medical facilities in the State of Illinois. The alleged violation. Davis, 440 U.S. at 631, 99 S. Ct. at 1383; facilities offer family planning education and medical care W.T. Grant, 345 U.S. at 633, 73 S. Ct. at 897. Defendants that includes the prescription of contraceptives, prenatal bear a heavy burden of persuading the court that a con- care, and delivery assistance for pregnant women. Her troversy is moot. United States v. Phosphate Export As- clinics receive approximately sixty requests for abortions sociation, Inc., 393 U.S. 199, 203, 89 S. Ct. 361, 364 (1968); each week. She would like to offer abortion services at W.T. Grant, 345 U.S. at 633, 73 S. Ct. at 897; Charles her clinics, and she has on staff physicians who are com- II, 749 F.2d at 457; Sanchez v. Edgar, 710 F.2d 1292, 1294-95 (7th Cir. 1983). petently trained and willing to perform such abortions. However, her facilities do not comply with the structural We note additionally that cessation of the allegedly il- requirements of the Act and regulations and cannot be legal conduct by government officials has been treated renovated to so comply without prohibitive cost. Accord- with more solicitude by the courts than similar action by ingly, she does not offer such services. private parties. According to one commentator, such self- correction provides a secure foundation for a dismissal II based on mootness so long as it appears genuine. See 13A Wright, Miller & Kane Federal Practice and Procedure We first consider whether certain of plaintiffs' challenges § 3533.7, at 353 (2d ed. 1984). have been mooted by the State's non-publicized policy of non-enforcement.5 It is well established that voluntary A. cessation of putatively illegal conduct ordinarily will not We believe that application of these general principles to the present circumstances mandates a conclusion that 5 We note that the defendants did not argue that portions of the plaintiffs' challenge to the second trimester hospitaliza- case were moot until their reply brief, arguing in their initial brief tion requirement is moot. As we have noted above, the only that the non-enforcement policy meant that the plaintiffs were defendants have conceded, at least since 1983, that this not being irreparably harmed by the statutory scheme. Nonethe- less, as we are under a duty to determine our own jurisdiction, requirement is unconstitutional under governing Supreme we must consider the question of mootness even if no party prop- Court decisions and is therefore not enforced. Plaintiffs erly raises it. have not attempted to counter the defendants' showing App. 13 App. 12 on this point, nor do we believe they could. The individual We believe that the defendants' now public policy of plaintiff Dr. Ragsdale testified that he was informed by non-enforcement of the hospitalization requirement, par- a State inspector that the hospitalization requirement was ticularly in view of the reasons therefor (i.e., that enforce- not being enforced and that after that time he began per- ment is barred by clear Supreme Court precedent), moots forming early second trimester abortions at his facility. any challenge to that requirement. While we share plain- tiffs' concern that the State has not acted to remove or Analogous assurances of discontinuance of the challenged amend the statute and regulations, we know of no author- conduct have been held to render challenges moot in other ity by which we can require it to do so. The most we cases. For example, in McRary v. Polythress, 638 F.2d could do, and all plaintiffs request of us, is to enjoin their 1308 (5th Cir.), cert. denied, 454 U.S. 865, 102 S. Ct. 325 enforcement. Federal courts do not, as a rule, enjoin con- (1981), election officials conceded that they had erred by duct which has been discontinued with no real prospect attempting to compel a political candidate to file certain that it will be repeated. Accordingly, the challenge to the financial disclosure reports and wrote the candidate aban- second trimester hospitalization requirement should have doning their request for such reports. This, according to been dismissed. Therefore we vacate the portion of the the court, mooted the challenge to the officials' action injunction that pertains to it. because "Appellant 'has presented no evidence creating a reasonable expectation that the [Commission] will repeat B. its purportedly unauthorized actions in subsequent elec- tions. Appellant's conclusory assertions that the actions Id. However, we do not believe that the challenge to the are capable of repetition are not sufficient. reporting requirement of the ASTCA and regulations is at 1310 & n.1 (quoting Illinois State Board of Elections moot. Although defendants testified that this requirement v. Socialist Workers Party, 440 U.S. 173, 187, 99 S. Ct. is no longer being enforced in light of Charles v. Carey, 983, 992 (1979). In Northern Virginia Women's Medical 579 F. Supp. 464 (N.D. III. 1983), we have reviewed that Center v. Balch, 617 F.2d 1045 (4th Cir. 1980), an even decision and cannot find anything in it which remotely more questionable assurance of discontinuance was held supports the conclusion that the requirement under chal- to moot the controversy. There, a local prosecuting at- lenge here was enjoined. The only reporting requirement torney's policy of not enforcing a state trespass statute addressed by that decision was section 11(d) of the Illinois against anti-abortion protestors who unlawfully entered Abortion Act, which required the reporting to the Depart- and blocked access to an abortion clinic was challenged ment of the name of any patient diagnosed as having com- as a denial of Equal Protection. The court held that the plications from abortion. The more general requirements prosecutor's assertion at oral argument that the non- here are quite different. Unlike its representations of non- enforcement policy had been abandoned, coupled with the enforcement of the other sections, the State produced no fact that prosecutions had in fact occurred during the pre-existing documentation of the policy. We share the pendency of the litigation, rendered the challenge moot. district court's concern that the State's position on this According to the court, "[s]ince the good faith of this provision is asserted only in this litigation. representation is not questioned, we conclude that the controversy between the Center and the commonwealth C. attorney is now moot and that it is not likely to be re- vived." Id. at 1049. The challenge to the application of the ASTCA and reg- ulations to first trimester abortions is similarly not moot. App. 14 App. 15 While the requirement is apparently no longer applied to right to privacy (and to abortion) as established in Roe the "occasional" abortion provider, the State continues to v. Wade, 410 U.S. 113, 93 S. Ct. 710 (1973), and its prog- maintain that it is free to apply the ASTCA to abortion eny. In Roe, the Court first set out the now familiar "tri- providers whose practice is "primarily devoted to" per- mester" approach: forming surgery, even if that "surgery" consists exclusive- (a) For the stage prior to approximately the end ly of first trimester abortions. This is in fact the situation of the first trimester, the abortion decision and its facing at least one of the named plaintiffs, Dr. Ragsdale. effectuation must be left to the medical judgment of Additionally, the evidence regarding the suspension/ rev- the pregnant woman's attending physician. ocation sanction in the MPA was, as we have noted, am- (b) For the stage subsequent to approximately the biguous. A representative of the Department merely tes- end of the first trimester, the State, in promoting tified that any complaint regarding this provision would its interest in the health of the mother, may, if it be "examined by the General Counsel's office for a deter- chooses, regulate the abortion procedure in ways that mination of whether there would be any enforcement ac- are reasonably related to maternal health. tion taken pursuant to that section." He additionally tes- tified that "to the best of [his] knowledge" the Depart- (c) For the stage subsequent to viability, the State ment would not enforce the section. While we admit that in promoting its interest in the potentiality of human it would be anomalous for the Department to take the life may, if it chooses, regulate, and even proscribe position that "occasional" abortion providers need not be abortion except where it is necessary, in appropriate licensed but that performance of such abortions could sub- medical judgment, for the preservation of the life or ject the physicians to revocation of their licenses to prac- health of the mother. tice medicine, the Department's position is sufficiently 410 U.S. at 164-65, 93 S. Ct. at 732. murky and the sanctions sufficiently severe, that we be- lieve a live controvery exists regarding this requirement. In elaborating on this approach, the Court noted that Doctors should not have to risk loss of their professional the State's interest in the health of the mother becomes licenses to explore the contours of the asserted non- compelling: enforcement position. 6 continued III court. Although no doubt its task was made more difficult by the On the merits,6 we must consider whether the require- lack of assistance from the parties, the district court undertook ments of the statutory and regulatory scheme violate the a thorough examination of those traditional factors, i.e., the lack of an adequate remedy at law, irreparable harm, balance of harms, likelihood of success on the merits, and the public interest. We 6 On appeal, various of the defendants and amici contend that confine our discussion to the likelihood of success on the merits, the district court did not properly weigh various of the factors that is, the governing legal standards and their relationship to the which are normally considered in issuing a preliminary injunction. facts found below for two related reasons. First, the balancing of We note that the presentation of the case below focused almost the other factors is typically reviewed on an "abuse of discretion exclusively on the constitutionality vel non of the statutory scheme standard" and we see no abuse, and second, we find insufficient or its component parts. None of the parties argued the traditional merit to any of the defendants' or the amicus' belated assertions factors governing the granting of preliminary relief to the district that this or that factor was given insufficient weight to add to (Footnote continued on following page) this already lengthy opinion. App. 16 App. 17 in the light of present medical knowledge, at ap- if the abortion is performed by medically competent per- proximately the end of the first trimester. This is so because of the now-established medical fact, ... that sonnel under conditions insuring the maximum safety of the woman.' Akron v. Akron Center for Reproductive until the end of the first trimester mortality in abor- Health, Inc., 462 U.S. 416, 430 n.12, 103 S. Ct. 2481, 2492 tion may be less than mortality in normal childbirth. n.12 (quoting Menillo, 423 U.S. at 11, 96 S. Ct. at 171). It follows that, from and after this point, a State may regulate the abortion procedure to the extent that Likewise, the Court upheld a state-required pathology the regulation reasonably relates to the preservation examination which required tissues removed by abortion, and protection of maternal health. Examples of per- like all other removed tissues, to be examined by a pa- missible state regulation in this area are requirements thologist. Planned Parenthood Association, Inc. v. Ash- as to the qualifications of the person who is to per- croft, 462 U.S. 476, 103 S. Ct. 2517 (1983). This was be- form the abortion; as to the licensure of that person; cause such an examination was considered "absolutely as to the facility in which the procedure is to be per- necessary" from a medical standpoint and " 'abnormalities formed, that is, whether it must be a hospital or may in the tissue may warn of serious, possibly fatal disor- be a clinic or some other place of less-than-hospital ders." Id. at 487-89, 103 S. Ct. at 2523-24. According to status; as to the licensing of the facility; and the like. the Court, certain regulations of even first trimester abor- tions that 'have no significant impact on the woman's This means, on the other hand, that, for the period exercise of her right [to have an abortion] may be per- of pregnancy prior to this "compelling" point, the at- missible where justified by important state health objec- tending physician, in consultation with his patient, is tives.' Id. at 489-90, 103 S. Ct. at 2524 (quoting Akron, free to determine, without regulation by the State, 462 U.S. at 430, 103 S. Ct. at 2492-93 (alterations by the that, in his medical judgment, the patient's pregnancy Court)). should be terminated. If that decision is reached, the judgment may be effectuated by an abortion free of The quoted language clearly indicates that, where first interference by the State. trimester abortions are involved, not only must the im- pact of the challenged regulation be insignificant in terms Id. at 163, 93 S. Ct. at 731-32. of the woman's exercise of her right, but also that the Since Roe, the Court, along with the lower federal regulation must be "justified by important state health courts, has on numerous occasions clarified the constitu- objectives." This is consistent with our own case law to tional standards which apply to regulations aimed at both the effect that once such regulations are shown to have first and second trimester abortions. Few restrictions on more than a de minimus impact on the abortion decision, first trimester abortions have been upheld. For example, the government must show a compelling basis for the law, the Court upheld a requirement that all abortions be per- i.e., that the burden is not undue or unjustifiable. Charles formed by a licensed physician. Connecticut v. Menillo, v. Carey, 627 F.2d 772, 777 (7th Cir. 1980) (Charles I), 423 U.S. 9, 96 S. Ct. 170 (1975) (per curiam). This require- on remand, 579 F. Supp. 464 (N.D. Ill. 1983).7 ment, apart from being endorsed in dictum in Roe, was upheld because "the State retains an interest in ensur- 7 Appellants make much of the fact that the district court con- ing the validity of Roe's factual assumption that 'the first nected the two parts of the Charles I dictum with "and" rather trimester abortion [is] as safe for a woman as normal than "that is," claiming that the district court thus applied an im- childbirth at term,' an assumption that 'holds true only proper standard. See 625 F.2d at 1230. This claim is meritless. (Footnote continued on following page) App. 18 App. 19 Appellants contend that the district court's application be "the functional equivalent of small hospitals," 625 F. of a "medical necessity" standard was error. We disagree. Supp. at 1216, and that these requirements "may be medi- First, we believe that a "medical necessity" standard, at cally detrimental." Id. at 1230 n.23. least as the term was used in the testimony below, is en- tirely consonant with the standards to be applied to reg- We note as well that the question whether some or all ulations regarding first trimester abortions. See Akron, of the requirements of the statute and regulations could 462 U.S. at 430, 103 S. Ct. at 2492-93 (such restrictions be constitutionally applied to early second trimester abor- must be "justified by important state health objectives"); tions is a more nettlesome one, but it is a question which Ashcroft, 462 U.S. at 487, 103 S. Ct. at 2523 (pathology we need not decide.8 The statute and regulations do not examination requirement upheld because "absolutely nec- essary" from a medical standpoint). Additionally, it is clear 8 A number of the regulations involved may well pass muster from a review of the transcript that when the experts under the less stringent standard of review applied to state regula- below testified that a requirement was not "medically nec- tion of second trimester abortions. That standard allows the state essary," they meant by that term that it had no real rela- to regulate second trimester abortions to the extent that the reg- ulation "reasonably relates to the preservation and protection of tionship to safety or health. See, e.g., R. Vol. I at 112 maternal health," but it may not "adopt abortion regulations that (testimony of Dr. Ragsdale) (certain provisions not medi- depart from accepted medical practice." Akron, 462 U.S. at 430-31, cally necessary because without "any real relationship to 103 S. Ct. at 2493. The experts who testified at hearing described the particular circumstances" of physician performing many of the requirements as "consistent with accepted medical abortions). According to the testimony, the minimum size practice." While it is true, as the district court found, that "[t]his requirements for examination rooms, procedure rooms, is not equivalent to a showing of medical necessity," such a show- ing is not required for regulations which apply only to the second recovery rooms, corridors and doors, for example, not only trimester. were not "medically necessary," but do not enhance the We note that the Supreme Court stated in Roe that the state's safety of the abortion procedure "in any way" or did not interest in maternal health during the second trimester extends have "any medical justification." R. Vol. I at 263-72 (tes- to "the facility in which the procedure is to be performed, that timony of Dr. Hern); see also R. Vol. I at 154 (testimony is, whether it must be a hospital or may be a clinic of some other of Dr. Ragsdale) (large procedure room "not only medical- place of less-than-hospital status; as to the licensing facility; and ly unnecessary but medically poor"). The district court the like." 410 U.S. at 163, 93 S. Ct. at 732. Further, in Simopoulos found, with full support from the record, that the physical v. Virginia, 462 U.S. 506, 103 S. Ct. 2532 (1983), the Court re- jected an attack on a criminal conviction, upholding against a plant requirements of the regulations required ASTCs to charge of facial invalidity a statute requiring all second trimester abortions to be performed in a "hospital," where that term was defined to include facilities which were not full-fledged acute care 7 continued hospitals. Thus, it appears that at least some licensing of facilities Charles I in fact reiterated the standard enunciated by the Su- performing second trimester abortions would be permissible. How- preme Court, that the state must justify its regulation with a com- ever, we caution that the Court in Simopoulos specifically noted pelling interest and show that the regulation is narrowly drawn that "[w]e need not consider whether Virginia's regulations are to express only that interest. See 627 F.2d at 776-78. Scrutiny of constitutional in every particular. Appellant has not attacked such laws always involves two questions: (1) how important the them as being insufficiently related to the State's interest in pro- asserted state interest is, and (2) how well the regulation is drawn tecting health." Id. at 513, 103 S. Ct. at 2539. Also, Simopoulos, to achieve only that interest. Charles I did not intend to suggest unlike the present case, involved a late second trimester abortion that the second inquiry was unnecessary, and appellants' reliance performed using the saline instillation method. on it for that purpose is misplaced. (Footnote continued on following page) App. 20 App. 21 distinguish between the two. Indeed, as written, due to American College of Obstetricians, 106 S. Ct. 2169, 2181 the (now unenforced) second trimester hospitalization re- (1986). quirement, they originally applied only to first trimester abortions. Accordingly, as we have in other cases, we ap- Defendants suggest that, because the regulations apply ply the legal standards applicable to restrictions on first to all facilities primarily devoted to surgery, we must trimester abortions. See Charles I, 627 F.2d at 782; review them under a different standard than if they had Friendship Medical Center, Ltd. v. Chicago Board of singled out abortions. We disagree. Defendants have cited Health, 505 F.2d 1141, 1149 (7th Cir. 1974), cert. denied, us to no cases, and we have found none, which would jus- 420 U.S. 955, 95 S. Ct. 1438 (1975). We are simply not tify such a distinction. In fact, Friendship suggests, albeit at liberty to insert the words "except with regard to first in dictum, exactly the opposite. 505 F.2d at 1153-54; see trimester abortions" into either the statute or the regula- also Birth Control Centers, Inc. v. Reizen, 743 F.2d 352, tions. To do SO would result in a scheme with little re- 361-62 (6th Cir. 1984) (applying strict scrutiny notwith- semblance to that enacted by the Illinois legislature or standing general applicability of regulations). the Department of Public Health. See Thornburgh v. We adhere to the statement in Friendship for several reasons. First, we cannot ignore the fact that the ASTCA 8 continued was enacted primarily with abortion clinics in mind and Much of the testimony below was to the effect that the require- only applied to outpatient surgical clinics generally in an ments of the regulations bore little relationship to safe performance effort to save the statute from unconstitutionality. See Pf. of early second trimester abortions as well as first trimester abor- Ex. 22-24 (minutes of ASTC Licensing Board meetings). tions. This should come as little surprise, since the medical pro- Secondly, the State cannot, merely by applying the ex- cedures utilized are quite similar if not identical. We remind the pedient and conclusory label "surgery" to a medical pro- State of the Supreme Court's admonition in Akron that: cedure, apply requirements which would be necessary to [I]f it appears that during a substantial portion of the second major surgical procedures in the abortion context where trimester the State's regulation "depart(s] from accepted medical practice," supra, at 2493, the regulation may not be they would be wholly inappropriate. It is as much a vice upheld simply because it may be reasonable for the remain- to treat abortion similarly to dissimilar procedures as it ing portion of the trimester. Rather, the State is obligated to is to treat it differently from analogous procedures. In make a reasonable effort to limit the effect of its regulations either case, imposition of burdensome requirements which to the period in the trimester during which its health interest are completely unnecessary to the performance of safe will be furthered. abortions is attempted. A prime example of this problem 462 U.S. at 434, 103 S. Ct. at 2495. is the fact that many of the physical plant requirements Thus, while the trimester approach remains the applicable legal of the regulations are designed with procedures to be per- framework for weighing the competing interests involved in the formed under general anesthesia in mind, although the abortion decision, it does not necessarily follow that all state testimony in this case clearly established that first and regulations of abortion which are keyed to it are reasonable. In- stead, the state should endeavor to draw its regulations designed early second trimester abortions of the type at issue here to further maternal health in medically relevant terms (for exam- are not usually performed using such anesthesia and that, ple, certain of the requirements of the statute involved here may in fact, the use of a general anesthetic increases the risk well make sense for late second trimester abortions which are per- of death and major complications from such procedures. formed under a general anesthetic, but not for simple "dilation and evaculation" abortions performed early in the second tri- With the standards enunciated above in mind, we now mester). turn to evaluation of the constitutionality of the challenged statutes and regulations. App. 22 App. 23 IV that this is not a great deal more than the cost of the A. pathology examination upheld in Asheroft, they seem to have missed the import of that case. The Court did not The State initially contends that the plaintiffs have not hold that the impact was SO small that the state was not met their threshold burden of showing an impact on the required to justify it at all. It merely held that, during abortion decision. We must reject this contention. The even the first trimester, requirements having an insignifi- district court found that the regulations at issue do sub- cant impact on the abortion decision were constitutional stantially burden the effectuation of the decision to have "where justified by important State health objectives." an abortion. Specifically, the lower court found that the Thus, the regulations at issue here, which have a greater regulations raised the cost of abortions, by $25-$40 for financial impact than that in Ashcroft, must be justified abortions performed at Dr. Ragsdale's clinic, and, more by at least similar state interests. importantly, that they would limit the availability of abor- tions in that, unless the regulations were enjoined, the Additionally, although the financial per-patient cost of clinic would close for lack of a suitable location that could compliance might not seem overwhelming, it is not the only burden which must be considered. The lack of avail- be renovated to comply with them.9 Additionally, the dis- trict court found that the regulations prevented individual ability of abortions caused by the up-front cost and dif- plaintiff Moe from offering abortion services at her clinic ficulty of obtaining a complying facility is at least as real because the cost of compliance was prohibitive. We can- and possibly more burdensome to women seeking abor- not say these findings are clearly erroneous. tions. Furthermore, there was testimony of the psycho- logical burdens which would result from having to undergo Dr. Ragsdale testified that he estimated compliance with an abortion in a hospital-like facility when the more psy- the regulations would entail a per-patient cost of between chologically comforting setting of a doctor's office would $25 and $40. 10 While the defendants point out, correctly, serve just as well from a medical standpoint. We cannot say that these burdens are "de minimus." Cf. Charles The Americans United for Life Legal Defense Fund, as amicus I, 627 F.2d at 777 ("direct interference" is shown where curiae, contends that, because individual plaintiff Dr. Ragsdale impact is not de minimus or where regulation imposes would have had to relocate his clinic regardless of the regulations restrictions "that did not already exist"). Therefore, they (due to an ostensibly unrelated business decision of his landlord), must be justified by important state health objectives. plaintiffs have presented no direct injury flowing from the chal- lenged government conduct. However, this argument misses the critical point that the regulations make difficult, if not impossible, B. the relocation of an existing abortion practice or the commence- ment of a new one. As such, we have little doubt that plaintiffs The first facet of the scheme we consider is the require- have established a sufficient injury both to satisfy Article III and ment that facilities performing first trimester abortions to warrant the grant of injunctive relief. be licensed at all. While this may not seem a particularly 10 Defendants place considerable emphasis on the allegedly erro- onerous requirement, we note Supreme Court precedent neous admission of Dr. Ragsdale's handwritten cost estimates. We suggests only that a licensing requirement may be per- need not decide whether these constituted inadmissible hearsay, missible in the second trimester. The Court stated in Roe however, because Dr. Ragsdale testified at length, and without that the state's interest in maternal health during the sec- objection, to the substance of the estimates. Therefore, the ad- mission of the written estimates themselves, if error, was surely ond trimester extends to "the facility in which the pro- harmless. cedure is to be performed, that is, whether it must be App. 24 App. 25 a hospital or may be a clinic of some other place of less- We realize that the Sixth Circuit upheld a similar gen- than-hospital status; as to the licensing of the facility; and eral licensing requirement in Reizen. However, in doing the like. 410 U.S. at 163, 93 S. Ct. at 732. By contrast, so, the court did not address a challenge based on the the Court stated that during the first trimester "the at- constitutional right to abortion, but rather an Equal Pro- tending physician, in consultation with his patient, is free tection challenge based upon the physician's right to prac- to determine, without regulation by the State, that, in tice. Accordingly, the court applied a highly deferential his medical judgment, the patient's pregnancy should be "rational basis" standard of review. 743 F.2d at 358-59. terminated. If that decision is reached, the judgment may As we have already held, such a standard of review is be effectutated by an abortion free from interference by not appropriate in this case. Additionally, none of the the State." Id. (emphasis added). evidence of the type mentioned above was apparently While we realize that the last quoted statement has present in Reizen. There, the district court found that a been qualified by the Court in subsequent decisions (that private physician was more likely to have direct control is, where the "interference" does not have a significant over staff and procedures, but that the absence of this impact and furthers important state health concerns), we control might characterize a "elinic." Such findings are nonetheless believe it retains force here. Thus, we are absent in this case. persuaded in this case that the State may not require Purely as a matter of the plain language of the statutory separate licensure of facilities primarily devoted to per- and regulatory scheme, once the licensing requirement forming abortions. falls, the remainder of the requirements fall with it (or, A primary factor which persuades us is that the State more properly, are inapplicable). The specific substantive has in no way shown that performance of first trimester requirements are not (leaving aside the unenforced re- abortions in physicians' offices rather than heavily regu- quirement that all abortions must be performed in an lated ASTCs in any way undermines the safety of the ASTC) applicable to abortions, per se, but rather to operation. We further note that Akron itself seems to re- ASTCs. In the alternative, however, we analyze those spe- ject such an argument. 462 U.S. at 429 n.11. The State cific substantive aspects of the regulations focused on at in fact basically concedes that it cannot prevent doctors trial which render the scheme unconstitutional as a whole. 11 from performing at least some abortions in their offices. To the extent that there is any basis for distinguishing 11 We do not decide whether particular provisions of the regula- tions not specifically mentioned in the text would, standing alone, between a doctor who occasionally performs an abortion pass constitutional muster. In particular, the pathology examina- in his office and one whose practice is primarily devoted tion required by the general regulations seems nearly identical to to such procedures, the regulations appear to run contrary that upheld in Ashcroft. Also the reporting requirement does not to sound health policy. All of the expert testimony in the appear particularly onerous, nor does it appear calculated to raise record is in agreement that the physician who performs the fear of harassment by physicians and patients by raising the spectre of public disclosure. Section 205.760 of the regulations many abortions in general will have more expertise and merely requires a report of each procedure performed in an ASTC therefore a better safety record. The State's attempt to within ten days, and that such reports be made in such a manner regulate experienced, and therefore safer, physicians, more and at such time so as not to avoid accurate reporting of com- heavily than the occasional abortion provider thus appears, plications. If complications become known to the ASTC, it is re- as the district court noted, to lack even a reasonable basis. quired to submit a supplemental report. Section 205.620, a non- abortion-specific reporting requirement, merely requires reporting (Footnote continued on following page) App. 26 App. 27 C. Court precedent or our own cases. In particular, we note The abortion-specific subpart of the regulations is of par- that section 205.730(a)(2) apparently requires the physi- ticular concern. Many of the requirements set forth in that cian who is to perform the abortion to also perform a subpart seem clearly contrary to either prior Supreme pregnancy test on the patient regardless of whether such testing had previously been done by another physician. We previously invalidated a similar "same doctor" require- 11 continued ment in an Illinois statute. See Charles I, 627 F.2d at 784, of the number and type of procedures performed, the number and type of complications reported, the number of patients requiring 786. The requirement in the instant regulation is, if any- transfer to hospitals, the number of patients returning for follow- thing, more burdensome and less justified than the one up, and the number of deaths. These requirements appear to be we invalidated there, which required only that the per- consistent with Planned Parenthood Association, Inc. v. Danforth, forming physician provide the patient with "a true copy" 428 U.S. 52, 79-81, 96 S. Ct. 2831, 2846-47 (1976). The requirements of her pregnancy test, rather than to possibly conduct a are considerably less stringent than those previously enjoined. In second test. For the same reasons as in Charles I, the particular, the name of the patient is in no way required to be provision in this case is invalid. disclosed to the State. Additionally, a number of the other general requirements seem The counseling requirements too suffer from constitu- as though they would place no real burden at all on the abortion tional defects. Section 205.730(b)(3) attempts to prescribe right. Requirements which may fall in this category might include the precise content of such counseling in mandatory terms the general provisions relating to personnel and administrative pro- applicable to all cases. The regulation states that counsel- cedures governing ASTCs, such as those calling for a written pol- icies and procedures manual, consulting committee, organization ing "shall include a discussion of alternatives, description plan, personnel policies, and maintenance of a sanitary facility. of the procedure to be performed, explanation of the risks Similarly, the operative care and post-operative care regulations and possible complications." We believe that this provi- may be in accord with accepted medical practice. Dr. Ragsdale sion, particularly the requirement of a "discussion of Item objected to many of these requirements as "stating the obvious." natives" is unconstitutional under the Supreme Court's However, so far as we are aware, there is no constitutional bar recent decision in Thornburgh v. American College of to "stating the obvious" even where abortion procedures are con- Obstetricians, 106 S. Ct. 2169 (1986). The requirement cerned. "that a specific body of information be given in all cases, Fewer of the abortion-specific regulations, as is evident from our irrespective of the particular needs of the patient, intrudes discussion in the text, fall in this category. However, there was testimony below that the counselor qualification requirements of upon the discretion of the pregnant woman's physician section 205.730(b)(2) were consistent with accepted medical prac- and thereby imposes the "undesired and uncomfortable tice. Additionally, subsection (1) of the same regulation merely re- straitjacket' which the Court has rejected. Id. at 2179 quires, in general terms, that some counseling be given prior to (quoting Planned Parenthood Association, Inc. v. Dan- the performance of an abortion (and that it occur in a room sepa- forth, 428 U.S. 52, 67 n.8, 96 S. Ct. 2831, 2840 n.8). The rate from the procedure room). As noted in the text infra, other informational requirements of the regulation are certain- aspects of the counseling requirements suffer from constitutional defects. Also, section 205.710 merely provides that "Abortions shall ly not as intrusive or as specific as those previously be provided to the public with the same standards of safety effec- stricken by the Court, but they are just as inflexible. Dr. tiveness, and regard for patients rights as any other health service." Ragsdale testified below that some of the information, par- Of course, we need not and do not decide the ultimate constitu- ticularly the "discussion of alternatives" might not be ap- tionality of any of the requirements mentioned above. propriate for some patients. We agree that "for a patient with a life-threatening pregnancy, the 'information' in its App. 28 App. 29 very rendition may be cruel as well as destructive of the physician-patient relationship." Thornburgh, 106 S. Ct. at Court: medical or surgical procedure. According to the 2180. We bear in mind that, during the second trimester at least, "the validity of an informed consent requirement If a physician is licensed by the State, he is recog- rests on the State's interest in protecting the health nized by the State as capable of exercising acceptable of the pregnant woman." Id. at 2179 (quoting Akron, 462 clinical judgment. If he fails in this, professional cen- U.S. at 443, 103 S. Ct. at 2499). Viewed in this light, the sure and deprivation of his license are available rem- provision at issue here may, like that in Thornburgh, "re- edies. Required acquiescence by co-practitioners has quire[ ] the dissemination of information that is not rele- no rational connection with a patient's needs and un- vant to such consent, and thus, it advances no legitimate duly infringes on the physician's right to practice. state interest." Id. at 2180. Id. at 199, 93 S. Ct. at 751. Another aspect of the counseling requirements is trou- We believe those principles are equally applicable here. bling. Section 205.730(b)(2)(D) requires that "counselors Accordingly, we hold that the requirement that counsel- shall have no financial interest in the patient's decision." ing be conducted by one who has no "financial interest" We find it impossible to read this provision in such a way in the patient's decision is unconstitutional. that it does not, at least in some cases, preclude the per- forming physician from providing the counseling. This, we D. believe, is fundamentally at odds with the emphasis placed on the patient-physician relationship by Roe and its prog- Of the requirements applicable to ASTCs generally, the eny. The woman desiring an abortion, according to those physical plant equipment and staffing requirements, in cases, is to reach that decision in consultation with "her particular, seem totally unjustified from a medical stand- responsible physician." Roe, 410 U.S. at 153, 93 S. Ct. point. The testimony regarding many of the physical plant at 727; cf. Akron, 462 U.S. at 449, 103 S. Ct. at 2502 requirements makes clear that they have "no medical jus- (striking down a requirement that the attending physician, tification whatsoever" when applied to first and early sec- rather than other professionals, must provide the requisite ond trimester abortions of the type involved in this case. counseling). The state cannot preclude that dialogue, or According to the testimony, the minimum size require- demand that others be a party to it merely because the ments for examination rooms, procedure rooms, recovery physician has a "financial interest" in the woman's deci- rooms, and corridors and doors not only are not "medical- sion. In all other areas of medicine, the state relies on ly necessary," but do not enhance the safety of the abor- the physician's professional and ethical obligations to pre- tion procedure "in any way" and do not have "any medi- vent his "financial interest" from clouding his perspec- cal justification." R. Vol. I at 263-72 (testimony of Dr. tive to the detriment of his patient. It may not do other- Hern); see also R. Vol. I. at 154 (testimony of Dr. wise merely because an abortion decision is involved. See Ragsdale) (large procedure room "not only medically un- Doe v. Bolton, 410 U.S. 179, 197-200, 93 S. Ct. 739, 750-51 necessary but medically poor"). We agree that the re- (1973). In Doe, the Court struck down requirements that quirements that ASTCs performing first and early second an abortion be approved by a hospital abortion committee trimester abortion(s) be "the functional equivalent of small and by two other physicians independent of the woman's hospitals" are not sufficiently justified by "important state own consulting physician because, inter alia, the state re- health objectives" to be sustained. quired such additional approval for "no other voluntary App. 30 App. 31 Additionally, the ventilation requirements of the regula- physician operating a facility to determine what is medical- tions, which require specific air pressure relationships be- ly required. Linder Dept. at 42. tween rooms and specific air change ratios are unrelated The structural, equipment, and staffing requirements of to the safety of first and early second trimester abortions. the regulations are quite similar to those invalidated in The purpose of such requirements is to prevent infection Reizen. See 743 F.2d at 364-65. They also bear a remark- from airborne bacteria. All of the medical experts, includ- able resemblance to the abortion-specific scheme we inval- ing defendants', testified that airborne bacteria simply is idated in Friendship. While the evidence in Reizen indi- not relevant to the procedures involved in this case, be- cated a per-patient cost increase considerably greater than cause the procedures do not involve an incision. The sole that in this case (Friendship did not consider particular- testimony to the effect that such requirements might be ized cost estimates), the regulations there, as here, would advisable came from the State's architectural expert, who have required considerable up-front expenditures. Also, apparently believed that an incision was required. It can as we have noted above, per-patient financial cost is not scarcely be doubted that such a witness lacks any exper- the only relevant burden. We have little trouble conclud- tise to enable him to form an opinion regarding the medi- ing that these requirements, which impose a substantial cal justification for a particular requirement.¹² burden and are not justified by health objectives, are More importantly, perhaps, the defendants failed to ad- unconstitutional. duce any evidence at all of a medical justification for the physical plant requirements. Although the defendants pro- E. test on appeal that plaintiffs' experts who testified as to the lack of medical justification were not building and con- We also believe that the "certificate of need" proceeding struction experts, the relevant test is whether the stan- requirement of the Health Facilities Planning Act is un- dards are "justified by important state health objectives." constitutional. The only interest which the State has ar- It seems clear to us that medical experts can offer tes- ticulated is the desire to keep costs down under the "cost- timony relevant to that standard, and it is questionable plus" disbursement method which was at one time used whether those without a health care background can. As by the State in making certain health care payments for we have noted above, only defendants' architectural ex- its residents. Apart from the fact that this interest no pert testified as to the need for the ventilation re- longer exists because the State has discontinued use of quirements. This witness similarly testified regarding this method, the State has never made such payments for room sizes, although he stated that the requirements were abortions. Furthermore, the interest cannot be said to be drafted with procedures involving general anesthesia in compelling in any event. While a state may have some mind. At one point, he testified that he relies on the interest in preventing wasteful duplication of resources, the interest must give way where the exercise of consti- tutional rights is concerned. Certainly it would be uncon- 12 Defendants' medical expert, Dr. Barton, lacked significant ex- stitutional for a state to require that anyone desiring to perience performing first trimester abortions. Those which he did publish a newspaper demonstrate "need" for the publica- perform were generally performed under a general anesthetic in tion, though it can scarcely be gainsaid that at least some a hospital setting. Due to his lack of experience relevant to the few involve wasteful duplication. Where the exercise of procedures at issue in this case, the district court properly ac- constitutional rights is concerned, the government may corded his testimony little weight. Defendants similarly do not rely play no role in determining whether outlets for their ex- on it heavily in this court. ercise are "needed." App. 32 App. 33 The unconstitutionality of the "certificate of need" pro- already so riddled with exceptions resulting from judicial ceedings as applied to ASTCs that wish to perform abor- decisions and non-enforcement policies as to be unintelligi- tions is exacerbated by the failure of the State to prevent ble. In such circumstances, we simply "cannot untangle the process from becoming essentially a public veto of the the constitutional from the unconstitutional provisions. ASTCs' existence. As we noted above, the proceedings Mahoning Women's Center v. Hunter, 610 F.2d 456, attended by the individual plaintiff physician was allowed 460 (6th Cir. 1979), vacated on other grounds, 447 U.S. to degenerate into a shouting match between abortion foes 918, 100 S. Ct. 3006 (1980). and advocates of free choice. The State's unwillingness As originally written, the statute and regulations rep- or inability to confine the proceedings to its even arguably resented at least a coherent, if unconstitutional, whole legitimate goals bolsters our conclusion that this require- which regulated all aspects of abortion practice in Illinois. ment cannot stand because it is not justified by any legit- However, as a result of various judicial decisions, and the imate State interest. defendants' change of enforcement policies in response to them, the scheme has long since lost that coherence. The V statute and regulations as written bear very little resem- While, as we have noted above, there may well be blance to the way they are currently enforced. As is clear facets of the statute and regulations which would indi- from portions of our opinion, we have at times encoun- vidually pass constitutional muster, supra nn. 8 & 11, we tered considerable difficulty discerning just what the law are constrained to affirm the district court's injunction of in Illinois is. Yet, the State expects physicians, on pain the scheme as a whole. Defendants, citing Zbaraz v. Har- of professional censure (possibly including loss of their itgan, 763 F.2d 1532, 1545 (7th Cir. 1985), appeal pending, licenses) and a $10,000 a day fine, to divine the contours No. 85-673 and Charles I, 627 F.2d at 779, urge that we of the rules under which they must operate. specifically analyze each provision and sever those portions Under these circumstances, we fully agree with the which are unconstitutional. However, in neither Zbaraz Sixth Circuit's decision in Mahoning Women's Center. nor Charles I were we confronted with a comprehensive There, in invalidating, in its entirety, a local ordinance scheme which either applied or not depending on whether that required "the functional equivalent of a hospital" for a licensing requirement could stand. In Zbaraz, we noted first trimester abortions, the court held "[i]n this situa- that severability applies only to "any provisions which can tion, we do not believe a useful purpose would be served be given effect without the invalid provisions," and that by attempting to rewrite the minor provisions of the or- "severance is improper if the unconstitutional provision dinance in order to make them constitutional." 610 F.2d is 'an integral part of the statutory enactment viewed in at 461. We could not agree more. its entirety.' 763 F.2d at 1545 (quoting Scheinberg v. Accordingly with the exception of the portion of the in- Smith, 659 F.2d 476, 481 (5th Cir. 1981)). Here, where junction regarding the second trimester hospitalization re- we are dealing with a licensing scheme and the provision quirement, which is VACATED As MOOT, the preliminary for separate licensure is itself invalid, not only can none injunction is of the other provisions "be given effect without the in- valid provisions," but the licensing provision is certainly AFFIRMED. "an integral part" of the scheme as a whole. Additional- ly, in neither Zbaraz nor Charles I was the scheme App. 34 App. 35 COFFEY, Circuit Judge, dissenting. A decade and one- half ago the Supreme Court announced "that the right of progeny that the individual states have the authority to en- personal privacy includes the abortion decision, but that sure that all surgical procedures, including first-trimester this right is not unqualified and must be considered against abortions, are performed "under conditions insuring max- important state interests in regulation." Roe v. Wade, 410 imum safety for the woman." Connecticut v. Menillo, 423 U.S. 113, 154, 93 S.Ct. 705, 727 (1973). Today, under the U.S. 9, 11, 96 S.Ct. 170, 171 (1975) (per curiam). Certainly guise of protecting the woman's constitutional privacy rights, states have the power and authority, if not the duty, to the majority holds that the State of Illinois' health ser- apply the same licensing standards to abortion facilities vices statutory scheme, enacted in an attempt to regulate as those applied to facilities performing similar surgical the ever-escalating costs of medical care without sacrific- procedures.2 I know of no law to the contrary. ing its citizens' health and safety, is unconstitutional. Spe- Moreover, the majority decision ignores the legislative cifically, now some 14 years after its enactment, the ma- intent and the historical context of the enactment of the jority declares the Ambulatory Surgical Treatment Center challenged provisions: section 16(1) of the Medical Prac- Act, 111½ Ill. Rev. Stat. 11 157-8.1 et seq. (the "ASTCA" or tice Act (the "MPA"), 111 III. Rev. Stat. 4433(1); the Am- the "ASTC Act") and the regulations promulgated there- bulatory Surgical Treatment Center Act, 111½ III. Rev. Stat. under unconstitutional, holding that the State may not re- 11 157-8.1, et seq., and the regulations promulgated quire licensure of facilities devoted primarily to performing thereunder; and the Illinois Health Facilities Planning Act, semi-complicated (minor) surgery, including first-trimester 111½ III. Rev. Stat. 19 1151, et seq., particularly 19 1155-1160. abortions. As an alternative approach, the majority chooses Research reveals that the Illinois legislature enacted $ 16(1) and carves out a select few ASTC regulations among var- of the MPA³ intending to limit the performance of abor- ious others, discusses their validity, and then proceeds to tions only to licensed ambulatory surgical treatment invalidate those regulatory sections of the ASTC Act that centers, hospitals, or similar facilities and expressed such apply to first-trimester abortion facilities in Illinois, stating intention by requiring licensure of "any facility in which that it was unable to sever those provisions of the Act a medical or surgical procedure is utilized to terminate it deemed unconstitutional from those that were constitu- a pregnancy, irrespective of whether the facility is de- tional. Thus, the majority strikes down the ASTCA and voted primarily to this purpose," (definitions section- baldly asserts that "the [statutory] scheme has long since lost coherence." Unfortunately, it is the majority's decision, rather than the Illinois legislative scheme, that lacks coherence.¹ I am convinced that under Roe and its 1 The majority's precise holding is confusing. On the one hand, 2 As demonstrated, infra, the most significant undisputed fact in the majority affirms the district court's preliminary injunction the record is that an abortion, regardless of the trimester in which which only enjoined Illinois from regulating ASTCs to the extent it is performed, is considered a surgical procedure, albeit a minor those facilities were performing abortions. On the other hand, the surgical procedure, accompanied all too frequently by concomitant majority apparently strikes down not only § 16(1) of the MPA, medical, physical, and psychological complications. but the ASTCA and the IHFPA as well, stating it could not "un- 3 As noted by the majority, § 16(1) of the MPA "allows for revo- tangle the constitutional from the unconstitutional," and further cation or suspension of the license of any physician who performs asserts that specific substantive aspects of the statutes and regula- an 'elective abortion' in any place other than a licensed Am- tions are unconstitutional and "render the scheme unconstitutional bulatory Surgical Treatment Center (ASTC), a hospital, or a facili- as a whole." ty run by the state or federal governments." (Emphasis added.) App. 36 App. 37 ASTCA, 9 157-8.3(A)).4 However, the legislature's primary the statutes and regulations] in order to make them con- purpose for enacting the Ambulatory Surgical Treatment stitutional. In so holding, the majority improperly sub- Center Act was to regulate and prescribe safeguards for stitutes its judgment for that of the legislature which the rapidly developing trend of cost-effective ambulatory enacted the statute because of its concern for the safety surgical medical services. The majority unfortunately dis- of its citizens. In the end, the majority decision severely regards this primary purpose which provided the impetus limits (or casts aside) the state's ability to implement cost- for the enactment of the ASTCA and through mere specu- effective schemes and regulate rapidly developing and lation holds that the ASTCA is solely an abortion stat- modern methods of providing medical services simply ute. Further, in its determination to do away with the because abortion (surgical) procedures may be involved. duly enacted legislation, the majority completely disre- The majority's misdirected holding ultimately protects gards the statute's severability clauses as if they didn't only the financial interests of abortion providers, like Dr. exist, stating it could not "untangle the constitutional from Ragsdale, rather than following the Supreme Court's lim- the unconstitutional" and thus refuses to give effect to ited mandate in Roe aimed at protecting the patient's the challenged acts.⁵ Rather than recognize and effectu- privacy rights. If we allow the majority's "reasoning" to ate the true intent and legitimate purpose of the acts and stand, surgeons, as well as other ASTC operators whose enjoin only those provisions which might impinge on a facilities are devoted primarily to the performance of abor- woman's limited right to terminate her pregnancy (§ 16(1) tions, will be allowed to operate without regulation while of the MPA, its companion clause in 9 157-8.3(A) and those ASTCs primarily performing other types of minor § 205.730(b)(2)(D) of the ASTCA regulations), the majori- surgical procedures will remain regulated (assuming the ty, in over-expansive language, declares, " '[W]e do not majority's decision merely affirms the district court's believe a useful purpose would be served by attempting preliminary injunction). Thus having treated facilities to rewrite minor provisions of the ordinance [in this case devoted primarily to abortions differently from those fa- cilities primarily devoted to other surgical procedures, the majority carves out an "abortionist exception" to the gen- 4 1 157-8.3 provides: eral rule that states can reasonably regulate how medical "(A) 'Ambulatory surgical treatment center' means any in- services are provided to its citizens. Ultimately, the ma- stitution, place or building devoted primarily to the mainte- jority in effect creates a legal vehicle for the non-abor- nance and operation of facilities for the performance of surgical tionists primarily performing other surgical procedures to procedures or any facility in which a medical or surgical pro- cedure is utilized to terminate a pregnancy, irrespective of challenge the ASTCA on equal protection grounds; for whether the facility is devoted primarily to this purpose. Such what rational basis exists for regulating ambulatory surgi- facility shall not provide beds or other accommodations for the cal centers differently than those facilities, like Ragsdale's overnight stay of patients. Individual patients shall be dis- abortion enterprise, devoted primarily to the termination charged in an ambulatory condition without danger to the con- of pregnancies? tinued well being of the patients or shall be transferred to a hospital." The task of a reviewing court, contrary to the majori- (Emphasis added to highlight the clause included in the ASTCA ty's reasoning, is, "of course, to resolve the issue restricting the availability of an abortion.) by constitutional measurement, free of emotion and pre- dilection." Roe v. Wade, 410 U.S. at 116, 93 S.Ct. at 709. 5 The severability clauses of the MPA, ASTCA, and the IHFPA are found respectively at 111 III. Rev. Stat. 4458, 111½ III. Rev. Consistent with this Supreme Court directive, our deci- Stat. 9 157-8.15, and 111½ III. Rev. Stat. 1 1166. sion must neither reflect pro choice nor anti-abortion sen- App. 38 App. 39 timent. The Illinois legislation at issue, specifically the sion nor its effectuation, and are justified with important ASTCA, is fundamentally different from other Illinois health objectives in mind. abortion-related legislation and merits thorough, reflective, When the alleged "tripartite" legislative scheme is thus and separate consideration. I would enjoin § 16(1) of the analyzed, neither a woman's right to terminate her preg- MPA and sever and further enjoin its companion clause nancy, nor the state's right to rationally regulate modern in 157-8.3(A) of the ASTCA requiring licensure of "any medical services for the protection of its citizens is ad- facility in which a medical or surgical procedure is utilized versely affected. Thus, I would reverse the district court's to terminate a pregnancy, irrespective of whether the fa- order enjoining Illinois' health services laws, except to the cility is devoted primarily to this purpose" because these extent it enjoined § 16(1) of the Medical Practice Act, its provisions prevent a physician from performing a first- companion clause in 9 157-8.3(A) of the ASTCA, and trimester abortion in his or her office. Under Roe and § 205.730(b)(2)(D) of the ASTCA regulations. its progeny this prohibition may very well be considered unconstitutional. I am convinced that the states, including I Illinois, are free to regulate ambulatory surgical treatment centers, including those performing abortions, as long as The majority decision properly notes that the "statutory abortions are not singled out from other, similar surgical and regulatory scheme is somewhat complex," but then procedures, subject only to the well-known rational basis proceeds to further confuse the challenged acts and their test governing social and economic legislation. Under the interrelationships, completely disregarding the legislature's rational basis test the ASTCA and IHFPA are constitu- intent regarding the various acts. The record of the legis- tional. Consistent with this analysis, I further evaluate lative history reveals that § 16(1) of the MPA, 111 III. Rev. the remaining abortion-specific statute sections and regu- Stat. § 4433(1), and the Ambulatory Surgical Treatment lations⁶ promulgated thereunder under the strict scrutiny Center Act (ASTCA), 111½ III. Rev. Stat. 157-8.1, et seq., test articulated in Roe and its progeny⁷ and would hold were initially companion bills to the initial comprehensive all but one of these constitutional because these statutory Illinois Abortion Act (IAA), 38 Ill. Rev. Stat. 81-11, et seq.⁸ sections and regulations neither burden the abortion deci- The IAA, § 16(1) of the MPA, and the ASTCA, were Senate bills (S.B.) 1049, 1050, and 1051, respectively. The legislative history further reveals that S.B. 1049 and S.B. 6 For example, 9 157-8.6-1 of the ASTCA requires that any cor- poration operating an ASTC "devoted primarily to providing facil- 8 The initial Illinois Abortion Law, 11 81-11, et seq., became ef- ities for abortion" must have a licensed physician who is "actively fective July 19, 1973, but was subsequently repealed by the Abor- engaged in the practice of medicine at the Center, on the board tion Law of 1975, effective October 30, 1979. The Abortion Law of directors as a condition of licensure." Additionally, subpart G of 1975 has been challenged on more than one occasion. See, e.g., of Title 77 of the Illinois Administrative Code contains abortion- Charles v. Carey, 579 F.Supp. 464 (N.D. III. 1983), aff'd in part, specific regulations. The validity of all but one of these provisions rev'd in part on other grounds, Charles v. Daley, 749 F.2d 452 is demonstrated, infra. (7th Cir. 1984), appeal dismissed sub nom. Diamond v. Charles, 7 I concur with the majority that the challenge to the second- 106 S.Ct. 1697 (1986). The initial IAA had a completely different trimester hospitalization requirement is moot. It appears that the purpose than the ASTCA and IHFPA. However, the majority con- majority effortlessly utilized and applied the severability clause of fuses the purposes of the IAA from that of the ASTCA and the Act to the second-trimester hospital requirement, but lost this IHFPA, and in doing SO clouds its ability to analyze the challenged analytical ability with respect to the other challenged provisions. statutes and regulations. App. 40 App. 41 1050 were integrally related; their purpose was to regulate vices. The minutes of the March 7, 1974, Ambulatory Sur- abortions in Illinois in light of, and in an attempt to com- gical Treatment Center Licensing Board meeting provide ply with, the Supreme Court's then-recent Roe and Doe relevant historical facts relating to the enactment of the decisions. As noted by the majority, § 16(1) of the MPA ASTCA:* provided for the "revocation or suspension of the license "In July 1971 a member of the hospital licens- of any physician who performs 'elective abortions' in any ing board, was appointed chairman of a committee place other than a licensed Ambulatory Surgical Treat- appointed to formulate regulations for those facilities ment Center (ASTC), a hospital, or a facility run by the that were presently unlicensable. Consideration was state or federal governments." Apparently, members of given to a large number of classifications and actually the Illinois legislature were concerned that the State there were 32 types of health facilities listed. would eventually be responsible for the cost of abortions On July 12, 1972, the final draft (after four drafts) performed on indigents in hospitals, so to reduce the of proposed standards were submitted to the Hospital State's anticipated abortion costs, less-expensive ASTC Licensing Board. [O]n August 16 [a member of facilities were included in the list of approved locations the Board] sent these proposed regulations forward for the performance of pregnancy termination procedures. [to the legislation liaison]. About August 1972 At the same time the legislature was debating the regula- [the Board] began to get involved more with the tion of abortions, ASTCs were just coming into existence and thus not regulated. Thus, S.B. 1051, an independent health regulatory bill creating and regulating ASTCs, was made a companion bill to the abortion bills. 9 The majority improperly relies on the ASTC Licensing Board minutes for the legislative intent of the act. The March 7, 1974, Contrary to the majority's assertions, the ASTCA, un- minutes conclude that "the legislation was written specifically for like the IAA and § 16(1) of the MPA, was not primarily regulation of the performance of abortions." On this basis, the ma- enacted for the purpose of regulating abortions. The rec- jority states, "First, we cannot ignore the fact that the ASTCA ord and legislative history reveal that the ASTC Act was enacted primarily with abortion clinics in mind and only ap- became law in Illinois in 1973 with the express policy of plied to outpatient surgical clinics generally in an effort to save the statute from unconstitutionality." Initially I point out that the insuring maximum safety in all medical procedures, pro- district court specifically and properly rejected the plaintiff's re- viding: quest to admit the minutes of the licensing board meeting as proof "for the better protection of the public health through of the legislature's intent. Tr. at 616. The district court's eviden- the development, establishment, and enforcement of tiary ruling was proper because "a court should adhere to the enacting legislature's purposes," Posner, The Federal Courts, p. standards (1) for the care of individuals in ambulatory 279 (1985), rather than post-enactment statements regarding legis- surgical treatment centers, and (2) for the construc- lative intent, particularly when those statements are not even tion, maintenance and operation of ambulatory surgi- made by the legislators involved. The district court received the cal treatment centers, which, in light of advancing licensing board minutes only for the limited purpose of establishing knowledge, will promote safe and adequate treatment the Board's state of mind regarding its enforcement procedures. of such individuals in ambulatory surgical treatment However, the historical facts regarding the development of the ASTC legislation and regulations are reliable, material, and rele- centers." vant to understanding the historical context in which the ASTCA III. Rev. Stat. ch. 111½, 1 157-8.2. Further, the ASTCA was enacted. Thus, I make limited reference to the minutes of was intended to regulate the cost-effective and rapidly the Board meeting only to draw attention to the historical facts contained therein. developing ambulatory outpatient surgical medical ser- App. 42 App. 43 question of abortions which became the primary tar- total national health expenditure, may be reduced get for discussion." directly and dramatically, at least on a short-term The significance of these Board minutes lies in the fact basis. By focusing on reducing inpatient surgery (ac- that as early as 1971 a state agency began preparing the counting for 60 percent of all hospital expenditures proposed regulations in response to the changing needs and about 25 percent of total health care expendi- and practices of medical services. Cost-effective "[f]ree- tures), ambulatory surgery may further reduce costs." standing ambulatory surgical centers (FASCs) are indepen- T. O'Donovan, Ambulatory Surgical Centers, Development dent entities which first opened in 1970. [T]hese and Management, p. 143 (1976). Further, by 1984 the facilities were conceived to fill a gap between the doc- ASTC trend was well established: tor's office and the hospital for minor surgical procedures not requiring overnight hospitalization." Note, Freestand- "The success of the Phoenix center precipitated rapid ing Emergency Centers: Regulation and Reimbursement, growth of a new type of facility for the delivery of 11 Am. J. L. & Med. 105, 118 (1985). 10 "The first success- ambulatory surgery, the freestanding, independent, ful freestanding ambulatory surgery center (FASC), [well ambulatory surgery center. Since that time, the Sur- known as Surgicenter], was opened in February 1970 in gicenter has become a model for an increasing num- Phoenix, Arizona." D. Ermann and J. Gabel, The Chang- ber of both independent and hospital-sponsored free- ing Face of American Health Care, Multi-Hospital standing ambulatory surgery programs. System, Emergency Centers, and Surgery Centers, 23 According to the Freestanding Ambulatory Surgical Medical Care 401, 406 (May 1985). As early as 1976 one Association (FASA), there are approximately 125 in- commentator observed: dependent freestanding ambulatory surgery centers, "From a societal point of view, perhaps the greatest 86 of which are members of FASA. According to impetus behind the ambulatory surgery concept is its FASA, which has been keeping statistics on its mem- potential for reducing the cost of services. This poten- bers since 1974, the membership performed 94,499 tial applies to both freestanding and hospital-based ambulatory surgery procedures in 1981, an increase facilities, the two major prototypes for ambulatory of 6 percent over the number performed in 1980. This surgery. By eliminating overnight hospital stays, ex- figure can be compared to 3.2 million ambulatory penditures for hospital services for inpatient health surgical procedures performed by hospitals offering care, which now account for about 40 percent of our ambulatory surgery in 1980." L. Burns, Ambulatory Surgery, Developing and Manag- ing Successful Programs, pp. 11-12 (1984). Lastly, I ob- 10 Much has been written regarding trends in ambulatory medical serve that freestanding ambulatory surgical centers are services, including ambulatory surgical treatment centers. See gen- properly subject to licensure and regulation (as are the erally T. O'Donovan, Ambulatory Surgical Centers, Development vast majority of medical facilities performing surgeries) and Management (1976); L. Burns, Ambulatory Surgery, Develop- throughout the country, and not only in Illinois. One ing and Managing Successful Programs (1984); M. Roemer, Am- bulatory Health Services in America (1981); D. Ermann and J. writer pointed out that: Gabel, The Changing Face of American Health Care, 23 Medical "a FASC must obtain a state CON [Certificate of Care 401 (May 1985); Pavarini, Setting Up and Operating Am- Need] in order to build the facility. In some states bulatory Care Centers in a Competitive Environment, 29 St. Louis U. L. J. 747 (1985). FASCs must also seek accreditation. In Illinois, FASCs are licensed and regulated by the State De- App. 44 App. 45 partment of Public Health. In Minnesota, surgical a license, some of these things are left open as to centers are covered by licensing rules. They must be regulations. The Department would like to take a staffed and equipped to handle surgical procedures, hand in that. This is something doctors have been anesthesia, and post-surgical care." urging us to do for a couple of years now, and am- Note, Freestanding Emergency Centers, Regulation and bulatory surgical treatment centers are in effect Reimbursement, 11 Am. J. L. & Med. 105, 118 (1985). out west. The idea is that they can be a great sav- ing to a patient. One of the big costs in a hospital, Obviously the Illinois Legislature was not privy to all if you remember it's kind of like a hotel which has this information regarding ambulatory surgical treatment special services and if you don't need that overnight centers in 1973, at the time it enacted the ASTCA. How- stay, you can save a great deal of money. So there's ever, as I stated, the record and legislative history reveal a great savings possible for the patient who needs that the legislature was well aware of the new and fast this kind of one-day surgical treatment. It does in- developing medical trend in outpatient ambulatory care clude abortion, and everything would be rather close- and specifically sought to regulate it. During the Senate ly regulated and inspected." debates, state Senator Wooten summarized S.B. 1051 as follows: (Emphasis added). Another state senator further pointed out that: "This is another one of those bills that cuts across lines in all kinds of ways. The Illinois State Medical "This bill is a good bill It's not related in any way Society asked that it be presented in a series with to abortions. It's sponsored by the Medical Associa- the two previous bills [S.B. 1049 and S.B. 1050], one tion. There's nothing wrong with ambulatory medical services." changing the law relating to abortion, the other chang- ing the Medical Practices Act. While this has a rela- Thus, contrary to the majority's mere speculative asser- tionship to abortion, it actually goes much beyond tions, the legislative history clearly and unequivocally sup- that. It [S.B. 1051] provides for the establishment and ports the proposition that the ASTCA was not enacted licensing of facilities which can perform minor sur- primarily to regulate abortions, but rather for the regula- gery. This would be things like tonsilectomy, hernias, tion of all semi-complicated (minor) surgical procedures abortions would be included, facial surgery, plastic performed in the rapidly developing ambulatory surgical surgery and so on. In other words procedures which treatment centers. Finally, I observe that just prior to would not require an overnight stay. And indeed the ASTCA's enactment, Senator Wooten specifically these ambulatory surgical treatment centers are for- stated: "The main thrust of [S.B. 1051] is to try to save bidden to keep patients overnight. However, those some money by getting minor surgical treatment out of of you who have kept close to medical practices know the hospital where it is hideously expensive and into a that untoward things can occur at any time, and so clinic." (Emphasis added). provision is made in here that doctors who function The record and the legislative history further reveal in such a center must also be licensed to practice that the Illinois Health Facilities Planning Act (IHFPA) in a hospital nearby so that if any complications oc- was enacted one year after the enactment of § 16(1) of cur they can quickly move the patient to that place. the MPA and the ASTCA and was clearly not part of Now, I handed out an outline to explain to you how a "tripartite" legislative scheme to limit the availability these things would work, definitions, they must get of abortions. The legislative history of the IHFPA reveals App. 46 App. 47 that it neither mentions abortions, nor referred to them, legislative scheme presently at issue, selectively carving nor was it enacted for purposes of regulating abortions. out the regulatory motive of the ASTCA to support its The IHFPA was intended to address the problem of ex- abortion theory of enactment. Thus, the majority states: pensive, overexpanded and underpopulated medical facil- "As originally written, the statute [I assume the ASTCA] ities and underutilized medical equipment in the State of and regulations represented at least a coherent, if uncon- Illinois. In the words of a legislator, the IHFPA was to stitutional, whole which regulated all aspects of abortion "provide a means for proper planning with local in- practice in Illinois." Having ignored or at least overlooked put and decision making to cut down on empty hos- the State's legitimate intent to regulate the new and rapid- pital facilities, nursing home facilities, sheltered care ly developing trend of ambulatory surgical medical ser- facilities and ambulatory surgical facilities." vices, the majority treats the ASTCA and the regulations (Emphasis added). promulgated thereunder as "minor" abortion provisions. Further, the majority rejects the basic principle of severa- Thus, the legislative history of the acts supports the bility when interpreting the construction of a duly adopted valid premise that the legislature intended to regulate legislative enactment which should give effect to the abortions when it enacted the Illinois Abortion Act. It State's legitimate purposes; and thus fails to apply the also appears that section 16(1) of the MPA and its com- correct legal standard to the different acts and regulations panion clause in 157-8.3(A) of the ASTC were probably and affirms the preliminary injunction. Thus, the majority enacted to prevent abortions from being performed in a limits and fails to effectuate the legitimate legislative pur- physician's office. On the contrary, there is no proof in poses behind the ASTCA. As a noted commentator has this record that either the ASTCA or the IHFPA were observed, limiting the scope of a legislature's intent con- enacted primarily to regulate abortions; rather, these laws stitutes undesirable judicial activism as much as a deci- were adopted to regulate the delivery of medical services sion construing a statute beyond its intended scope. See to its citizens and to attempt to prevent and control the Posner, Statutory Interpretation, in the Classroom and further unnecessary overexpansion of Illinois' medical fa- in the Courtroom, 50 U. Chi. L. Rev. 800, 822 (1983). The cilities. That the ASTCA was initially a companion bill majority's failure to give full effect to the real and legiti- to the abortion bills is more of a historical coincidence mate legislative intent to regulate ASTCs is the basis of relished by political opportunists who, in this case, ap- my dissent. parently fully utilized it to their advantage. As the min- Recently, this court observed: utes of the licensing board reflect, for whatever their worth: "Without the public interest in abortions, we would "In Immigration and Naturalization Service v. not have any of the present legislation." That is to say Chadha, 462 U.S. 19, 103 S.Ct. 2764, 77 L.Ed.2d 317 that the state legislators and other interested parties who (1983), the Supreme Court stated that unconstitution- were primarily interested in regulating ambulatory medi- al provisions in a statute shall be severed if it ap- cal services would not have been able to enact the legisla- pears that the legislature would have enacted consti- tion without the statewide and even nationwide interest tutional provisions of the statute independently of in the abortion question at the time. those provisions. 103 S.Ct. at 2774 (citing Buckley v. Valeo, 424 U.S. 1, 108, 96 S.Ct. 612, 677, 46 The majority, acting and reasoning as if living in a social L.Ed.2d 659 (1976))." and economic vacuum (overlooking the developing nation- wide trend of ASTCs), ignores the dual purpose of the App. 48 App. 49 Zbaraz v. Hartigan, 763 F.2d 1532, 1545 (7th Cir. 1985), 'Ambulatory Surgical Treatment Center' means aff'd, 108 S.Ct. 479 (1987). The Illinois laws in question any facility in which a medical or surgical procedure all have their own severability provisions; thus, it is clear is utilized to terminate a pregnancy, irrespective of that the Illinois legislature intended that the constitutional whether the facility is devoted primarily to this pur- provisions of the acts should be given effect even if other pose provisions were held unconstitutional. Accordingly, I ana- Significantly, the defendant-appellant, the State of Illinois, lyze the challenged statutes and regulations recognizing asserts that it no longer enforces § 16(1) of the MPA. Ad- that "severance is improper [only] if the unconstitutional ditionally, the majority observes that Illinois alleges that provision is 'an integral part of the statutory enactment viewed in its entirety.' Id. (quoting Scheinberg v. Smith, the clause in 9 157-8.3(A) above is no longer being en- forced, noting that: 659 F.2d 476, 481 (5th Cir. 1981)). On the other hand, the challenged provisions which burden a woman's right to "Since 1981, the [ASTC] act and regulations have privacy may be severed as long as the severed provisions been applied only to facilities which are primarily do not affect "the essential purposes of the act." Id. devoted to the performance of surgical procedures (including abortions). This enforcement policy was adopted in response to Village of Oak Lawn v. Mar- II cowitz, 86 Ill.2d 406, 427 N.E.2d 36 (1981), which The abortionist, Dr. Richard M. Ragsdale, plaintiff-appel- refused to enforce, in a criminal proceeding, that por- lee, testified at the preliminary injunction hearing that the tion of the local ordinance which incorporated the alleged "[f]irst and major burden [affecting a woman's right ASTCA definition of an ASTC which covered 'any to terminate her pregnancy] is simply the requirement for facility where a medical or surgical procedure is per- an independent licensure as an abortion provider." This formed for the termination of pregnancy, regardless licensing requirement, applicable to any physician who of whether the facility is primarily devoted to that wishes to perform an abortion outside of a hospital, an purpose.' ASTC, or other regulated facility, regardless of the gesta- tional period of the embryo or fetus, was created when The majority holds, and I agree, that Illinois' alleged non- the legislature enacted § 16(1) of the MPA and its com- enforcement policy does not render the issues moot. panion clause in the ASTC definitions section. As previ- Although several justices have persuasively argued that ously noted by the majority, "[s]ection 16(1) of the Medical Roe v. Wade and its progeny articulate an "unworkable Practice Act allows for revocation or suspension of scheme for constitutionalizing the regulation of abortion," the license of any physician who performs an 'elective Thornburgh v. American College of Obstetricians, 476 U.S. abortion' in any place other than a licensed Ambulatory 747, 814, 106 S.Ct. 2169, 2207 (1986) (Justice O'Connor, dis- Surgical Treatment Center a hospital, or a facility senting), or represent a "venture fundamentally mis- run by the state or federal governments." The following guided since its inception," Id. at 786, 106 S.Ct. at 2192 clause in 9 157-8.3(A) of the ASTCA is the companion (Justice White, dissenting), this court should be bound by clause to § 16(1) of the MPA, and brought all surgeons Roe and its progeny. The Supreme Court's recent Thorn- who wished to perform abortions under the ASTCA li- burgh decision "reaffirm[ed] the principles laid down in Roe censing and regulatory scheme: and Akron." Id. at 759, 106 S.Ct. at 2178. Thus, we analyze the abortion licensing requirement created when the Illinois legislature enacted § 16(1) of the MPA and its companion provision contained in the ASTC definition of App. 50 App. 51 ambulatory surgical treatment center, 1 157-8.3(A), under of pregnancy. Until that time, a pregnant woman the standards articulated in Roe and its progeny. must be permitted, in consultation with her physi- cian, to decide to have an abortion and to effectuate "In Roe v. Wade, the Court held that the 'right of that decision 'free of interference by the State.' privacy, founded in the the Fourteenth Amend- ment's concept of personal liberty and restrictions This does not mean that a State never may enact upon state action, ... is broad enough to encompass a regulation touching on the woman's abortion right a woman's decision whether or not to terminate her during the first weeks of pregnancy. Certain regula- pregnancy.' tions that have no significant impact on the woman's exercise of her right may be permissible where jus- The Court also has recognized, because abortion is tified by important state health objectives. a medical procedure, that the full vindication of the From approximately the end of the first trimester woman's fundamental right necessarily requires that of pregnancy, the State 'may regulate the abortion her physician be given 'the room he needs to make procedure to the extent that the regulation reason- his best medical judgment.' ably relates to the preservation and protection of maternal health.' At the same time, the Court in Roe acknowledged The State's discretion to reg- ulate on this basis does not, however, permit it to that the woman's fundamental right 'is not unquali- adopt abortion regulations that depart from accepted fied and must be considered against important state medical practice. [The Court has] rejected a State's interests in abortion.' But restrictive state reg- attempt to ban a particular second trimester abor- ulation of the right to choose abortion, as with other tion procedure, where the ban would have increased fundamental rights subject to searching judicial ex- the cost and limited the availability of abortions amination, must be supported by a compelling state without promoting important health benefits. ... If interest. [The Supreme Court] recognized two a State requires licensing or undertakes to regulate such interests that may justify state regulation of the performance of abortions during this period, the abortions. health standards adopted must be 'legitimately re- First, a state has an 'important and legitimate in- lated to the objective the state seeks to accomplish.'' terest in protecting the potentiality of human life.' City of Akron v. Akron Center for Reproductive Health, Although this interest exists 'throughout the 462 U.S. 416, 426-431, 103 S.Ct. 2481, 2490-93 (1983) (cita- course of the woman's pregnancy,' it becomes tions omitted) (emphasis added). compelling only at viability, the point at which the fetus 'has the capability of meaningful life outside the Initially one observes that the abortion licensing require- mother's womb.' ment as it exists pursuant to § 16(1) of the MPA and the ASTCA definition, fails to distinguish between first and Second, because a State has a legitimate concern second trimester abortions; thus, it prohibits the perfor- with the health of women who undergo abortions, 'a mance of first-trimester abortions in physicians' offices. State may properly assert important interests in safe- The record reveals that a woman's qualified right under guarding health [and] in maintaining medical stan- Roe to terminate her pregnancy is very probably imper- dards.' [The Court further] held in Roe, however, missibly burdened because surgeons who would otherwise that this health interest does not become compelling perform first-trimester abortions out of their offices are until 'approximately the end of the first trimester' App. 52 App. 53 precluded from doing SO. Dr. Ragsdale, an abortionist and rates of abortions performed in hospitals. Based on the a board-certified obstetrician and gynecologist, testified medical experts' testimony, it appears probable that first- that outpatient abortions, whether performed in a physi- trimester abortions could be safely performed in the sur- cian's office or a clinic, were as safe as an abortion per- geon's office. Thus, it appears that § 16(1) and its com- formed in a hospital setting. panion clause in 1 157-8.3(A) of the ASTCA would limit Plaintiffs additionally called another alleged abortion ex- the availability of abortions by precluding the performance pert, Dr. Warren Martin Hern, a doctor and general prac- of abortions in a physician/surgeon's office. titioner without board certification in the specialty of ob- In Akron the Supreme Court noted that where the stetrics and gynecology. Hern testified that first-trimester abortion law "increased the cost and limited the availabil- abortions, performed six to eight weeks from the last ity of abortions," such a law would probably interfere with menstrual period are "probably the safest surgical pro- the woman's decision to have an abortion as well as its ef- cedure being performed in the United States in this cate- fectuation. Akron, 103 S.Ct. at 2492-93. Further, although gory of procedures.' Dr. Hern further testified that the dictum, the Supreme Court noted "that the medical evi- safest surgical method of first-trimester abortion was the dence suggests that until approximately the end of the "vacuum aspiration" method. This procedure is basically first trimester, the state's interest in maternal health would "a suction removal of the uterine contents." not be served by regulations that restrict the manner in The State of Illinois' expert, Dr. John J. Barton, a board- which abortions are performed by a licensed physician." certified specialist in the fields of obstetrics and gynecol- Id. at 2492 n.11. The Court further observed that "un- ogy, also testified that first-trimester abortions performed complicated abortions generally may be performed in a in outpatient facilities (such as physicians' offices or ASTCs) physician's office or an outpatient clinic up to 14 weeks present no greater risk than the risks and complication from the first day of the last menstrual period." Id. (American College of Obstetricians and Gynecologists (ACOG), Standards for Obstetric-Gynecologic Services 54 11 Dr. Hern defined "in this category of procedures" as "pro- (5th ed. 1982)). In light of the Supreme Court's caveat cedures that involve invasion of a body cavity or a major organ in Akron noting the probability that physicians can per- of some kind." form first-trimester abortions in their offices; given the 12 Dr. Hern noted that the fatality rate for abortion was about defendant's policy of nonenforcement regarding § 16(1) five per one million, whereas, the case fatality rate for term de- of the MPA and its companion clause in the ASTC, livery was about 11 per 100,000 live births, which meant that the 9 157-8.3(A), requiring the licensure of any facility per- risk of term birth is approximately 25 times greater in terms of forming even one abortion; and after evaluating the evi- risk of death than abortion. Dr. Hern compared the abortion sur- dence presented during the preliminary injunction hearing gery risk factors to the risk factors of other types of outpatient surgery. He testified that "some estimates indicate tonsillec- which established that first-trimester abortions performed tomies are at least twice as dangerous as abortions." Similarly, in a controlled outpatient setting, including a physician's Hern stated only that he consulted a colleague who informed him office, probably were as safe as abortions performed in that laparoscopic surgery resulted in a death rate of two per hospitals, I would selectively enjoin the enforcement of 100,000. Hern testified: "Laparoscopic surgery involves the intro- § 16(1) of the MPA and its companion clause in the ASTCA duction of a laparoscope into the abdominal cavity. A laparoscope is definition without destroying the entire act because it is a tube, a metal tube, that is hollow and is something that permits the physician to look through it into the cavity and is introduced more likely than not that the plaintiffs would prevail on through the umbilicus, with or without operating instruments." the merits in light of present Supreme Court precedent. App. 54 App. 55 In so holding, I agree with the Illinois Supreme Court e.g., Village of Oak Lawn v. Marcowitz, 427 N.E.2d at decision in Village of Oak Lawn v. Marcowitz, 86 Ill. 2d 42.14 So construed, the ASTCA fully effectuates the legis- 406, 427 N.E.2d 36 (1981), which also held that the ASTCA lature's primary purpose for its enactment, i.e., to reg- definition was constitutionally invalid as incorporated in ulate the rapidly developing trend of cost-effective am- a local ordinance which "closely resemble[d] the state bulatory surgical medical units. Thus, the State of Illinois [ASTC] act and implementing regulations adopted by the remains free to license any facility pursuant to the "abor- Department of Health." Id. at 38. The local ASTC ordi- tion neutral" ASTCA "devoted primarily to the mainte- nance also required an "initial license fee of $5,000, plus nance and operation of facilities for performance of sur- annual renewal fees of $2,000." Id. at 39. In Marcowitz gical procedures," including an abortion facility, like Dr. the Illinois court, foreshadowing the caveat in Akron, Ragsdale's, devoted primarily to the performance of abor- stated: tions. 15 As with other social and economic legislation, the "Given the substantial licensing fee required and the test traditionally applied is whether or not the law has detailed regulation involved, it seems inevitable that a "rational relation" to a valid state objective. See Wil- medical practitioners who might otherwise perform liamson v. Lee Optical Company, 348 U.S. 483, 491, 75 abortions for their regular patients, but whose facil- S.Ct. 461, 466 (1955). Thus, I would apply the "rational ities were not primarily devoted to surgery, would relation" test to the now "abortion neutral" ASTCA. choose not to qualify under the ordinance. The right The majority, however, disagrees and would apply the of a woman considering a first-trimester abortion to strict scrutiny test relying on mere dictum in Friendship seek the advice and services of her obstetrician, gyne- Medical Center Ltd. v. Chicago Board of Health, 505 F.2d cologist, or other physician in whom she has trust 1141 (7th Cir. 1974), cert. denied, 420 U.S. 997 (1975). and confidence may not be so drastically curbed." There the court observed: Id. at 42. "Furthermore, any proposed regulation, even if ap- Further, both § 16(1) of the MPA and the impermissible plied universally to all similar medical procedures, definition clause in the ASTCA,13 can easily be severed from their respective acts without affecting the legisla- 14 As I discuss, infra, the abortion-specific 9 157-8.6-1, as well ture's "essential purposes" for the acts' enactments. See as the abortion-specific regulations, are also severable; however, Zbaraz, 763 F.2d at 1545. The MPA is virtually unaffected all but one of these provisions survive the strict standard articu- and capable of being enforced independently of § 16(1) and lated in Roe. as such will continue to be used inter alia to revoke or 15 The majority baldly asserts that Dr. Ragsdale's practice con- suspend a malfeasant physician's license. Similarly, the sists exclusively of first-trimester abortions even though the record ASTCA becomes "abortion neutral" once the invalid reveals that Ragsdale performed some 40,000 abortions between clause is removed from the definition of an ASTC. See, 1973 and 1985. Up until the Illinois court's 1982 decision in Poe v. Illinois Department of Public Health, No. 78-C-4126 (N.D. III. 1982), which found the second-trimester hospital requirement un- 13 The unconstitutional clause of 1 157-8.3(A) of the ASTCA to constitutional, Ragsdale limited his practice to the performance of first-trimester abortions. However, Ragsdale testified that subse- be severed reads as follows: quent to Poe, he began performing second-trimester abortions. This "or any facility in which a medical or surgical procedure is obviously makes economic sense since the physician had the avail- utilized to terminate a pregnancy, irrespective of whether the able licensed ASTC and would only lose income by refusing to facility is devoted primarily to this purpose." perform second-trimester abortions. App. 56 App. 57 because of the fundamental right of a woman to pro- onstrated in part I, the legislative history establishes the cure an abortion during the first trimester, would contrary; the primary purpose of the ASTCA was to reg- have to meet a compelling governmental interest re- ulate the new cost-effective ASTCs in which semi-compli- quirement. Thus, any general health regulations cated (minor) surgery was performed. In effect the ma- which would apply to first-trimester abortions would jority puts the cart before the horse because it rests its have to be limited so as to give effect to the fun- analysis of the ASTCA on the quagmire of legal dictum damental rights as established by Roe and Doe; that set forth in Friendship which ultimately clouds and con- is, not be burdensome on a woman's right to decide fuses its analysis of the ASTCA. to abort a pregnancy. By this we mean that in all The majority further states: probability nothing broader than general requirements as to the maintaining of sanitary facilities and general "Secondly, the state cannot, merely by applying the requirements as to meeting minimal building code expedient and conclusory label 'surgery' to a medical standards would be permissible." procedure, apply requirements which would be neces- Id. at 1153-54. sary to major surgical procedures in the abortion con- text where they would be wholly inappropriate. It Initially, I point out that Judge Fairchild, concurring, is as much a vice to treat abortion similarly to dis- rejected the Friendship majority's dictum, stating: similar procedures as it is to treat it differently from "Nevertheless, regulation of the safety of all these analogous procedures." procedures, incidentally including first-trimester abor- The majority's conclusory statement is incredible in light tions, through imposition of generally applicable reg- of the record. First of all, the plaintiff's own medical ex- ulations, would seem to be a valid exercise of the perts testified that an abortion was a surgical procedure state's interest in protecting health and need only (regardless of the type of abortion method used). On direct satisfy the traditional [rational basis] test of judicial examination Ragsdale stated that an abortion "is a minor scrutiny imposed in this area." surgical procedure." Tr. at 420. Dr. Hern also testified Id. at 1155 (Fairchild, J., concurring). Because Friend- that an early abortion-one performed six to eight weeks ship's dictum to the contrary "was not refined by the fires from the last menstrual period-"is the safest surgical of adversary presentation," it "was not a fully measured procedure being performed." Tr. at 241 and 260. Likewise, judicial pronouncement," and thus "not authoritative." it was Dr. Barton's expert opinion that an abortion con- United States v. Crawley, 837 F.2d 291, (7th Cir. stituted an operation, Tr. at 452, and abortions "are clas- 1988). This caveat is particularly applicable here where sified as minor surgical procedures." Tr. at 467. Dr. Hern we are construing a legislative act regulating a broad field further stated that an abortion is a surgical procedure of medical services, including minor surgical procedures. categorized as a procedure "that involve[s] invasion of a body cavity or a major organ of some kind." Tr. at 241. The majority gives two reasons, unsupported by this In reaching its conclusion that the state applied the "ex- record, for relying on the Friendship dictum: "First, we pedient and conclusory label 'surgery'' to an abortion, cannot ignore the fact that the ASTCA was enacted pri- the majority once again disregards the record and strays marily with abortion clinics in mind and only applied to far afield from its area of legal competence and makes outpatient surgical clinics generally in an effort to save medical judgments and pronouncements that are more the statute from unconstitutionality." However, as I dem- properly reserved to those expertly trained in the medical App. 58 App. 59 scientific fields such as physicians, surgeons, nurses, cedures, it would not be impermissible to make them medical technicians, etc. specifically applicable to abortion clinics." Further, I observe that the courts have consistently Id. at 1358. alluded to abortions as a surgical procedure. In Roe, for Moreover, in Baird v. Department of Public Health, 599 example, Justice Stewart noted that the "protection of F.2d 1098 (1st Cir. 1979), the court upheld a state licen- the health and safety of a woman" was a legitimate ob- sure statute applicable to any clinic providing medical, jective, amply sufficient "to permit a state to regulate surgical, dental, restorative, or mental hygiene services, abortions as it does other surgical procedures." Roe v. including facilities offering only first-trimester abortion Wade, 410 U.S. at 170, 93 S.Ct. at 735 (Justice Stewart, con- services. The First Circuit held: "There is room under curring). Still more recently, in Akron the Supreme Court Roe for states to apply the same licensing standards to observed that the district court had found that "an abor- abortion facilities as they apply to like facilities perform- tion generally is considered a 'minor surgical procedure." ing medically analogous procedures." Id. at 1102 (empha- Akron, 462 U.S. at 444, 103 S.Ct. at 2500 n.35. Thus, the sis added). See also Westchester Women's Health Organi- evidence establishes that an abortion is a surgical procedure, zation v. Whelan, 475 F.Supp. 734, 739-40 (S.D.N.Y. 1979); albeit a semi-complicated (minor) surgical procedure. Sig- Abortion Coalition v. Michigan Department of Public nificantly, the ASTCA was intended to regulate all minor Health, 426 F.Supp. 471, 477 (E.D. Mich. 1977); Hallmark surgical procedures, including all types of abortive proced- Clinic v. North Carolina Department of Human Re- ures performed in an ASTC; this the majority fails to recog- sources, 380 F.Supp. 1153, 1157 (E.D.N.C. 1974), aff'd on nize. There is no reason to apply strict scrutiny in this other grounds, 519 F.2d 1315 (4th Cir. 1975). Thus, Illinois' situation. There is no language in the Supreme Court's de- laws licensing and regulating ASTCs are proper. cisions upholding the majority's speculative and implicit theory that the Court intended to strike down social and The law is very clear that a state has right to enact economic legislation such as the ASTCA in the name of Roe legislation for the protection of its citizens. See Quilici or a woman's limited right to terminate her pregnancy. v. Village of Morton Grove, 695 F.2d 261, 274 (7th Cir. 1982) (Coffey, J., dissenting), cert. denied, 464 U.S. 863 Further, in Hodgson v. Lawson, 542 F.2d 1350 (8th Cir. (1983). The Supreme Court specifically stated: 1976) (per curiam), the court addressed the issue of whether a state could subject the abortion decision, even "It is elemental that a state has broad power to es. during the first trimester, to regulations promulgated by tablish and enforce standards of conduct within its the state board of health, including licensing requirements. borders relative to the health of everyone there. It is a vital part of a state's police power. The state's The Eighth Circuit concluded: discretion in that field extends naturally to the reg- "A state can impose the same regulations on a clinic, ulation of all professions concerned with health.' specifically built to perform abortions during the first trimester, that are imposed on other clinics that per- Barsky v. Board of Regents, 347 U.S. 442, 449, 74 S.Ct. form surgical procedures requiring approximately the 650, 654 (1954). Thus, I am persuaded by the logic of same degree of skill and care as the performance of Judge Fairchild's concurrence in Friendship, rather than first-trimester abortions. As long as the regulations by the unsupported and speculative conclusions of the ma- applying to abortion clinics are the same as those ap- jority, as well as the reasoning of the First and Eighth plied to other clinics performing similar surgical pro- Circuits, that under Roe and its progeny a state has not only the power and authority, but also the duty, to reg- App. 60 App. 61 ulate all medical facilities, particularly any facility where removed, the potential for future difficulties in bearing any surgical procedures are performed (including first- children, and also the possibility of sexual sterility. It trimester abortions) as a valid exercise of its interest in defies reason to allow the state to license an ASTC per- protecting the health and welfare of its citizens while en- forming hernia surgery, cataract removals, and repairs of suring that the facilities will provide "conditions insur- a torn or detached retina, but not permit the state to ing maximum safety for the woman" who has decided to license ASTCs primarily performing abortions when there terminate her pregnancy. Connecticut v. Menillo, 423 U.S. are many similar risks involved in the myriad types of at 11, 96 S.Ct. at 171. abortive procedures. The ASTCA and the regulations promulgated there- Lastly, the majority asserts that it is irrational for the under were intended to do just that, to protect the safe- state to regulate the full-time provider of abortions (those ty of its citizens, and is reason sufficient enough to sus- primarily performing abortions) more heavily than the oc- tain the validity of the statute. As in many other surgical casional provider. While it may be true that the full-time procedures, there are a variety of similar medical and abortionist may consider himself or herself "more skilled" physical risks involved in having an abortion. Depending and SO theoretically need less regulation, the majority upon a particular woman's characteristics and develop- overlooks that a state with limited resources may rational- ment, medical and psychological problems may very well ly choose to direct its energies to improving the lot of arise during the abortion procedure that only an experi- the greatest number. For example, if the state, after the enced, well-trained, board-certified obstetrician and gyne- proper enactment of legislation, chooses to regulate ASTCs cologist is capable of recognizing and effectively treating and reduce the risk of minor surgery (as well as its cost) in a properly designed, constructed, equipped, maintained, for 100,000 of its citizens, and more instrusive regulation managed and medically approved facility. Depending upon of occasional providers would help only 2,000, the state the gestational duration of the embryo or fetus, such com- may very properly deal with the 100,000 first. Further, plications include, but are not limited to, trauma, perma- the cost of regulation per patient will be lower if the state nent damage to vital organs, dysfunction of the cardiovas- concentrates its attention on high-volume businesses; sure- cular or respiratory system requiring cardio-pulmonary ly this constitutes a rational relation to a permissible end. resuscitation, internal bleeding or hemorrhaging of the The majority's treatment of the ASTCA and the IHFPA uterine wall, cervical lacerations, uterine perforation, em- under the strict scrutiny test is just another way the ma- bolism of the blood vessels, allergic reaction to medica- jority circumvents and fails to effectuate the purpose of tion or anesthesia, if administered, and even the perma- the ASTCA, i.e., to regulate changes in the provision of nent impairment of reproductive organs. Other medical medical services. Essentially, the majority substitutes its factors that must be considered in making an informed judgment for that of the legislature; this is truly unfor- abortion decision include the type of abortion to be per- tunate in this case since courts should defer above all to formed (dilation and curettage, dilation and vacuum as- a legislature's judgments on social and economic matters. piration, dilation and evacuation, hysterotomy, or hyster- See Dandridge v. Williams, 397 U.S. 471, 90 S.Ct. 1153 ectomy), the woman's medical history, her reaction to (1970). Lawyers who are now judges are neither trained previous surgical procedures, her tolerance to certain nor experienced in the medical disciplines possibly related medications, the chance that she is an RH-negative fe- to abortion procedures, e.g., obstetrics, gynecology, psy- male, the likelihood of contracting a uterine infection, the chiatry, pathology, general surgery, or emergency medi- chance that the placenta and fetus will not be completely cine. Nor are judges versed in the nuances of the prac- App. 62 App. 63 tices and techniques of the medical profession and thus sibility of [guaranteeing its citizens adequate, cost- are ill-equipped to substitute their views regarding what effective but safe, medical services.]" is medically adequate, proper, or antiseptic. "As recent- Id. at 487, 90 S.Ct. at 1162-63 (citations omitted) (emphasis ly stated by the Supreme Court, 'there certainly is no added). See also In re U.S. ex rel. Missouri State High reason to think judges are better qualified than appropri- School, etc., 682 F.2d 147 (8th Cir. 1982) ("Once a rational ate professionals in making such decisions.' St. Mary of relationship exists, and it exists here, judicial scrutiny Nazareth v. Dep't of Health & Human Services, 698 F.2d must cease. Whether the rule is wise or creates undue 1337, 1346 (7th Cir. 1983) (quoting Youngberg v. Romeo, individual hardship are policy decisions better left to legis- 457 U.S. 307, 323, 102 S.Ct. 2452, 2462 (1982)). However, lative and administrative bodies"). this majority decision is replete with such medical asser- tions. For example, the majority states, "The testimony Lastly, because the courts "have returned to the orig- regarding many of the physical plant requirements make inal constitutional proposition that courts do not substitute clear that they have 'no medical justification whatsoever' their social and economic beliefs for the judgment of legis- when applied to first and early second trimester abortions lative bodies," Ferguson v. Skrupa, 372 U.S. 276, 730, of the type involved in this case." However, the ASTCA 83 S.Ct. 1028, 1031 (1963), the "abortion neutral" ASTCA was intended to regulate all minor surgical procedures, is entitled to presumptive validity. It is a well-recognized and the legislature is free to enact reasonable legislation. principle that Under these circumstances, and in light of the real risks "The question, whether a law be void for its repug- that accompany minor surgical procedures, including abor- nancy to the constitution, is, at all times, a question tions, it is dangerous for the majority to substitute its of much delicacy, which ought seldom, if ever, to be judgment as to what constitutes necessary and/or appro- decided in the affirmative, in a doubtful case. The priate ASTC regulations. Although in Dandridge the Su- court, when impelled by duty to render such a judg- preme Court was concerned with welfare assistance pro- ment, would be unworthy of its station, could it be grams, the following admonition is as applicable today as unmindful of the solemn obligations which that sta- it was then: tion imposes. But it is not on slight implication and "We do not decide today that the [Illinois] regula- vague conjecture, that the legislature is to be pro- tion is wise, that it best fulfills the relevant social nounced to have transcended its powers, and its acts and economic objectives that [Illinois] might ideally to be considered as void. The opposition between the espouse, or that a more [reasonable] system could not constitution and the law should be such that the be devised. Conflicting claims of morality and intel- judge feels a clear and strong conviction of their in- ligence are raised by opponents and proponents of compatibility with each other." almost every measure, certainly including the one Fletcher v. Peck, 10 U.S. (6 Cranch) 85, 128 (1810) (em- before us. But the intractable economic, social and phasis added). 'Every possible presumption is in ... even philosophical problems presented by fregulating favor of the validity of a statute, and this continues until medical services] are not the business of this [c]ourt. the contrary is shown beyond a rational doubt.' Powell The Constitution may impose certain procedural safe- v. Pennsylvania, 127 U.S. 678, 684 (1887) (quoting In re guards upon [the regulatory] system But the Sinking Fund Cases, 99 U.S. 700, 718 (1879)). See also Constitution does not empower this [c]ourt to second- Kelley v. Johnson, 425 U.S. 238, 247, 96 S.Ct. 1440, 1445- guess state officials charged with the difficult respon- 46 (1976) (Justice Rehnquist, now Chief Justice, stated that App. 64 App. 65 state decisions regarding social legislation are "entitled to the same sort of presumption of legislative validity as III are state choices designed to promote other aims within However, even if Roe and its progeny were to apply the cognizance of the State's police power."). As the Su- to the ASTCA and IHFPA as asserted by the majority, preme Court recently observed in Pension Benefit Guar- the Act would still be constitutionally valid. The holding anty Corp. v. R.A. Gray & Co., 467 U.S. 717, 729, 104 of Roe and its progeny S.Ct. 2709, 2717 (1984): "does not mean that a state never may enact a reg- "It is by now well established that legislative Acts ulation touching on the woman's abortion right during adjusting the burdens and benefits of economic life the first weeks of pregnancy. Certain regulations that come to the Court with a presumption of constitu- have no significant impact on the woman's exercise tionality, and that the burden is on one complaining of her right may be permissible where justified by of a due process violation to establish that the leg- important state objectives." islature has acted in an arbitrary and irrational way. See, e.g., Ferguson v. Skrupa, 372 U.S. 726, 83 S.Ct. Akron, 462 U.S. at 430, 103 S.Ct. at 2492. The plaintiffs asserted that the ASTCA and IHFPA substantially bur- 1028, 10 L.Ed.2d 93 (1963); Williamson v. Lee Op- dened the woman's right to terminate her pregnancy in tical Co., 348 U.S. 483, 487-488, 75 S.Ct. 461, 464, three ways: (1) by limiting the availability of abortions; 99 L.Ed. 563 (1955).' (2) by increasing the cost of an abortion; and (3) by re- (quoting Usery v. Turner Elkhorn Mining Co., 428 U.S. quiring the provider to fulfill the certificate of need re- 1, 15, 96 S.Ct. 2882, 2892 (1976)). See also Rhinebarger quirements subjecting the abortionist to a "public veto v. Orr, No. 87-1738, slip op. at 3 (7th Cir. February 4, of his [abortion] services." As I previously noted, $ 16(1) 1988) (Chief Judge Bauer observed: "It is well established of the MPA and its companion clause in 9 157-8.3(A) of that congressional legislation 'adjusting the burdens and the ASTCA could very well be considered unconstitutional benefits of economic life' are presumed constitutional and and therefore should be enjoined. Thus, the licensure of that 'the burden is on one complaining of a due process facilities allegedly devoted primarily to the performance violation to establish that the legislature has acted in an of abortions does not limit the availability of abortions arbitrary and irrational way.' "). Here, the plaintiffs-appel- since many other surgeons, if they SO choose, could per- lees have not demonstrated that the Illinois legislature form first-trimester abortions in their offices.¹⁶ Thus, the acted in an arbitrary or irrational way when enacting the ASTCA cannot be said to limit the availability of abor- ASTCA and the IHFPA. Thus, within the parameters of tions. Further, the possibility that Ragsdale's clinic might Roe, I am convinced that the state is free to regulate possibly close does not significantly, if at all, affect the abortions to the same extent it regulates similar surgical availability of abortions. The plaintiffs stated that "there procedures. I fail to understand how the majority holds are approximately 65,860 abortions performed in Illinois otherwise since the Supreme Court has never held that annually." Ragsdale v. Turnock, 625 F.Supp. 1212, 1219 Roe holds to the contrary. Thus, I would reverse the district court's order preliminarily enjoining the ASTCA and the IHFPA. 16 In Akron the Supreme Court reaffirmed its trimester approach. Thus, I am convinced that the state could constitutionally require that all second-trimester abortions be performed in an ASTC. Even the plaintiffs' experts testified that the risks of an abortion rise substantially in the second trimester. App. 66 App. 67 (N.D. III. 1985). Of these, Ragsdale performs some 3,400 The district court found the second burden on a woman's to 3,500 annually, or some 5 percent. Additionally, there right to terminate her pregnancy created by the ASTCA are some 42 to 44 ASTCs in Illinois and "approximately licensing requirement was that the licensing requirement half of these provide abortions services." Id. However, raised the cost of an abortion "by $25 to $40 for abor- the district court found that Ragsdale was the only avail- tions performed at Ragsdale's clinic." The defendants able abortionist in his area. The record reveals that Rags- argue that the district court erroneously relied on hear- dale initially testified that he was the "only provider" of say for the basis of its factual findings regarding the in- abortions in his area. Subsequently, he qualified his testi- creased cost. I couldn't agree more since the defendants mony, stating he was "primarily, and, in many ways, the objected throughout the hearing to the relevancy and ad- only abortion provider" in the area. However, Ragsdale missibility of Ragsdale's alleged cost sheets. The alleged concluded, stating: "To the best of my knowledge, no one cost sheets consisted of Ragsdale's musings after allegedly else intends" to perform abortions in the area. These discussing tentative plans to move his facility with con- statements, contrary to the district court's finding that tractors and other vendors. Ragsdale, a physician and sur- Ragsdale was the "only" abortion provider, do not estab- geon, is no more an expert in cost accounting, contracting, lish that abortions would be unavailable in the area if architecture, etc., than the respective experts in these Ragsdale had to close his facility (because he failed to areas are knowledgeable about the problems and practice lease or purchase a new facility). Inferring from the high of surgery and/or medicine. Thus, just as the majority re- volume of abortions performed at Ragsdale's clinic, it is jected the defendant's architectural expert's testimony apparent that the efficiency of the clinic had reached that regarding the medical "need for the ventilation require- of an "economy of scale," making it uneconomical for ments," so too should the majority, on proper balance, other physicians to enter the abortion market in the area. reject Ragsdale's compliance cost estimates. However, assuming arguendo, that abortionists receive On the other hand, assuming arguendo, that Ragsdale's anywhere from $250 to $400 per abortion,¹⁷ it is unlikely cost-related testimony was properly received in evidence, that another operator (like Ragsdale) would not perform I am convinced that the important state health objective abortions in the area in the event Ragsdale's business of insuring safe, yet cost-effective, medical service by re- closed. The physician-surgeon entrepreneur could not ig- quiring minimum engineering and construction standards nore Ragsdale's apparent potential annual gross income justified the de minimis financial impact that compliance from abortions alone, approximately $875,000 ($250 per with the regulations places on the cost of an abortion. The abortion X 3500 abortions per year). The district court's majority inaccurately asserts that "Dr. Ragsdale testified finding that the closing of Ragsdale's clinic would make that he estimated compliance with the regulations would abortions unavailable is mere speculation and clearly erro- entail a per-patient cost of between $25 and $40." The neous. record reveals that Dr. Ragsdale testified that he esti- mated the added costs of complying with the regulations over and above the costs required simply to relocate his 17 Plaintiff's counsel stated during closing argument before the current practice in such a manner as he deemed appro- district court that the fee charged in a hospital for an abortion priate for his needs, as $25.21 per patient. (Ragsdale Tr. was $1,000 and that the hospital fee was 2.5 to 4 times greater 400-01). This added cost of $25.21 certainly cannot be con- than the cost of an abortion performed in an outpatient facility (including a physician's office). Thus, according to plaintiff's counsel, sidered as significantly more than the $19.40 (less than an outpatient abortion costs $250 to $400. a $5 difference) increase per abortion for tissue examina- App. 68 App. 69 tion upheld by the Supreme Court in Ashcroft because This brings us to the third burden allegedly impinging "in light of the substantial benefits that a pathologist's upon a woman's qualified right to terminate her pregnan- examination can have, this small cost is clearly justified." cy, i.e., Certificate of Need (CON) for Ragsdale's ASTC 462 U.S. at 490, 103 S.Ct. at 2524. Moreover, it should and the related public hearing required pursuant to the be pointed out that the increased cost testified to herein, IHFPA. 18 The majority unbelievably holds the certificate unlike the one in Ashcroft, would at best only be tempo- of need requirement unconstitutional for the reason, inter rary and not one that would remain ad infinitum. Dr. Rags- alia, that the public hearing accompanying a certificate dale admitted that "much of the debt would be retired after of need created a public veto of a woman's qualified right two to five years." Thus, after two years the fee increase to an abortion. The record establishes unequivocally that would be reduced to $10.90 per patient, and after five years Ragsdale's landlord, a hospital, wished to terminate its to a mere $3.40 per patient. I am convinced that the mini- lease with Ragsdale because Ragsdale failed to refer pa- mum engineering and construction design requirements al- tients to the hospital. Ragsdale applied to the State of legedly at issue, which ensure only that all surgical pro- Illinois, pursuant to the ASTCA and IHFPA, for a license cedures performed in ASTCs, including first-trimester abortions, are performed in clean, sanitary, and safe struc- tures are a substantial benefit to the health and safety 18 Pursuant to 11 1155-1160 of the IHFPA, and as noted by the of patients, and the miniscule financial impact referred to majority, "anyone seeking to open an ASTC [must] obtain a cer- is clearly de minimis and justified. tificate of need for the facility from the Department of Public Health after a public hearing and a 120-day review period." A One last observation respecting the cost of an abortion. CON is granted if the State Board finds After searching the record, I found no evidence establish- "(1) that the applicant is fit, willing, and able to provide a ing the cost of an abortion performed in a doctor's of- proper standard of health care service for the community with fice. However, the plaintiff's counsel during closing argu- particular regard to the qualification, background and character ment before the district court stated that the costs of an of the applicant, (2) that economic feasibility is demonstrated abortion performed in a hospital ($1,000) was 2.5 to 4 in terms of effect on the existing and projected operating budget of the applicant and of the health care facility; in terms times as costly as that of one performed in a surgeon's of the applicant's ability to establish and operate such facility office or in an outpatient clinic. These figures reflect that in accordance with licensure regulations promulgated under outpatient abortion costs, including those performed in a pertinent state laws; and in terms of the projected impact on physician's office, range from $250 to $400 each. Thus, the the total health care expenditures in the facility and communi- $250 cost of an abortion performed in Ragsdale's ASTC, ty, (3) that safeguards are provided which assure that the establishment, construction or modification of the health care even if operating in full compliance with the Act, may facility is consistent with the public interest, and (4) that the in fact represent the low end of the abortion market price. proposed establishment, construction or modification is con- This proposition supports my earlier observation that sistent with the orderly and economic development of such Ragsdale's clinic, because of its efficiency, dominated the facilities and is in accord with standards, criteria, or plans local market. Further, assuming that Ragsdale's increased of need adopted and approved pursuant to the provisions of cost per abortion was $25.21, the percentage increase is Section 12 of this Act for such facilities for comprehensive in the range of 6 to 10 percent, certainly de minimis. It health care in the community, area, or State served by such facilities." is not as if the price of an abortion went from $250 to 111½ III. Rev. Stat. 1 1156 (emphasis added). In this manner the $500, a significant burden. state has attempted to reduce skyrocketing health care costs by limiting the expansion of unnecessary medical facilities. App. 70 App. 71 for his new facility. After a full investigation and subsequent requires the management or owner of an ASTC to formu- to holding public hearings, the state agency found that there late written policies and a procedures manual. Dr. Rags- was in fact a need for Ragsdale's medical services. At dale described this requirement as standard medical and the public hearing a number of citizens protested against administrative practice. Other administrative and organiza- abortions stating their pro-life positions. It stretches the tional regulations, such as those requiring written safety imagination that one would write that the exercise of plans (§ 205.510), appointment of a qualified consulting one's First Amendment rights to object to an issue be committee and medical director (§ 205.230), and written treated somehow as creating a burden on a woman's right personnel policies (§ 205.310), as well as those requiring to an abortion. The majority, however, asserts that "the sanitary conditions (§ 205.420) and proper disposal of all state's unwillingness or inability to confine the proceedings materials from the abortion procedure and maintenance [the public hearings on Ragsdale's CON for his ASTC] of the equipment in good working order (§ 205.410) are to its even arguably legitimate goals bolster our conclusion merely enunciations of universally recognized standard [that the CON] requirement cannot stand." This statement practice for performing surgical procedures in an outpa- flies in the face of the fact that the state after due and tient facility. As Dr. Ragsdale conceded on direct examina- considerate deliberations absent emotion or hysteria ob- tion, most of the regulations of this type simply "stated jectively analyzed and in fact found that need existed for the obvious" and in no way impinged upon a woman's Ragsdale's medical services. Although I have previously decision, much less her right, to an abortion. Moreover, expressed that an individual, including an abortionist, the building design and construction requirements contained should be free from picketing in front of his private home, in the ASTC regulations reflect proper engineering design see Schultz v. Frisby, 807 F.2d 1339, 1355 (7th Cir. 1986) and practice from a medical service point of view and ac- (Coffey, J., dissenting), reh'g granted and decision vacated, cepted minimum standards for medical facilities. Examples 818 F.2d 1284 (7th Cir. 1987), aff'd by equally divided vote include requirements for testing and balancing heating, 619 F. Supp. 792, 822 F.2d 642 (7th Cir. 1987), cert. ventilation, and air conditioning systems to ensure that granted, 1988 U.S. L.W. 2211 (January 11, 1988), public they are in proper working condition (§ 205.1510), insula- hearings are a different matter. Public hearings are an tion in appropriate locations (§ 205.1520), and a minimum open forum where all citizens should have the right to ceiling height of eight feet with appropriate exceptions be heard in an organized manner in our democratic form for certain rooms, such as storage rooms (§ 205.1400). I of government. That some open forums or demonstrations believe that the state has more than just a compelling sometimes "degenerate into a shouting match" is nothing interest, and in fact has an overriding interest, in ensur- new to our right of free speech, much less to our national ing that any and all ASTCs performing any surgical pro- system of justice and ordered liberty. I fail to comprehend cedures, including first-trimester abortions, are designed the majority's contrary view. and constructed to meet basic engineering standards for Further, the record in this case establishes that the medical facilities in order that all fairly sophisticated ASTCA regulations in question place no burden whatso- medical procedures are conducted "under conditions en- ever on a woman's decision to terminate her pregnancy suring the maximum safety" of the patient. Connecticut in the first trimester because they reflect nothing but the v. Menillo, 423 U.S. at 11, 96 S.Ct. at 171. common, accepted, and approved standards of medical Dr. Hern, the plaintiff's alleged expert witness at trial, practice and procedure as testified to by the medical ex- testified that "90 to 95 percent of all first-trimester perts. For example, § 205.240 of the ASTC regulations procedures in this country are performed by vacuum App. 73 aspiration technique of some kind," and are "the safest even under Roe and its progeny the ASTCA and surgical procedure[s] now performed." The record also thus. IHFPA must be held constitutional. established that other abortion procedures, such as the saline, urea, and installation techniques (involving insert Finally, turning to those abortion-specific ASTCA regu- ing a needle into the amniotic cavity, withdrawing fluid. lations: I would hold that all but one of these abortion- and installing a saline solution within the amniotic cavity) specific regulations survive Roe's scrutiny. Initially, I were also being performed in ASTCs. These abortion pro would hold that 9 157-8.6-119 properly requires a physi- cedures have a higher complication and fatality rate than clan actively engaged in practice at an ASTC be on the Inward of directors of any ASTC "devoted primarily to pro- other abortion procedures, such as the vacuum aspiration and dilation and evacuation methods. Since more compli viding facilities for abortions" as a condition of licensure. Since the Supreme Court's decision in Connecticut v. cated and involved abortion procedures which require Menillo, it has been clear that states can require that only close supervision, control and regulation are also per. formed in ASTCs, I am persuaded that the state can. physicians perform abortions. Illinois' additional require- ment that a practicing physician/surgeon be on the board should, and must regulate its ASTCs in order that it of an ASTC primarily involved in providing abortion ser- might protect its citizens from possible serious medical vices simply guarantees that a physician be involved in problems which could very easily arise. The State of Illi- the business decisions of the board of directors (exclusive nois, through its legislators, has the authority, if it so of the patient-doctor abortion decision) and thus ensure determines, to require a higher standard for the opera safe medical procedures and practices. Further, Dr. Rags- tion of these clinics, including attending and supervising date testified that 9 157-8.6-1 did not burden the woman's personnel, building specifications and design, as well as nght to an abortion. Additionally, Margaret Moe, who maintenance, in order that it might protect its citizens. desired to offer abortions out of her clinic, is now free just as the State of Wisconsin has the authority to re in light of the probable unconstitutionality of § 16(1) of quire higher standards for its prisons and the State of the MPA and its companion clause in the ASTC defini- Georgia to protect its inmates if it so wishes. Cf. Wis. twn) to do so as long as the clinic is not devoted primarily Administrative Code §§ HHS 302, et seq. with Georgia to surgical procedures. If Moe chooses to incorporate her Code Annotated § 42-5-50, et seq. Similarly, the State of chnic as an ASTC, she, without any trouble, will be able Illinois can pass legislation mandating more all-inclusive to retain a surgeon performing abortions at her clinic to immunization requirements for school-age children than serve on her ASTC board of directors. This requirement those required by the State of Missouri. Cf. Illinois Re neither limits the availability nor increases the cost of an vised Statute Chapter 111.5, 22.11 and Illinois Adminis trative Code Tit. 77, § 696.10 with Missouri Revised Stat ute § 167.181. 10 Paragraph 157-8.6-1 provides: The Illinois legislature has determined that the ASTCA "Abortions-Licensed physicians portant social and economic laws for the betterment and the and the IHFPA, by their very enactment, are very im 1 6.1 Notwithstanding any other provision of this Act, any corporation operating an Ambulatory Surgical Treatment Center protection of its citizens. Neither the ASTCA nor a devoted a primarily to providing facilities for abortion must have IHFPA burden a woman's qualified right to terminate im- physician, who is licensed to practice medicine in all of its and both Acts further serve the state's branches at and is actively engaged in the practice of medicine sure of the Center." the Center, on the board of directors as a condition to licen- pregnancy, portant interest in the health and welfare of its citizens. App. 74 App. 75 abortion performed at an ASTC and in fact serves the "Recordkeeping and reporting requirements that are important state interest in protecting the health of its reasonably directed to the preservation of maternal citizens. Thus, 9 157-8.6-1 is constitutional. health and that properly respect a patient's confiden- Further, the record reveals that those regulations ad- tiality and privacy are permissible. Recordkeep- dressing operative care do not burden a woman's right ing of this kind, if not abused or overdone, can be to an abortion. Section 205.530(c) of the ASTC regulations useful to the state's interest in protecting the health requires that all tissues removed during surgery be ex- of its female citizens, and may be a resource that is amined by a qualified consulting pathologist. The Supreme relevant to decisions involving medical experience and Court upheld an almost identical regulation in Ashcroft. judgment As so regarded, we see no legally sig- The Court held that a Missouri regulation requiring all nificant impact or consequence on the abortion deci- tissues surgically removed (including tissue removed dur- sion." ing first-trimester abortions) be examined by a pathologist Id. at 80-81, 96 S.Ct. at 2846 (footnote omitted). Further, "reasonably related to generally accepted medical standards Dr. Hern, one of the plaintiffs' alleged experts, testified and 'further[s] important health-related state concerns.' specifically that the reporting of statistics "is essential to 462 U.S. at 487, 103 S.Ct. at 2523 (quoting City of Akron, public health evaluation." Thus, the reporting requirements 462 U.S. at 430). The Court stated: "As a rule, it is ac- at issue are consistent with the Court's holding in Dan- cepted medical practice to submit all tissue to the exam- forth and are constitutional. ination of a pathologist. This is particularly important Other abortion-specific regulations require a determina- following abortion, because questions remain as to the long- tion of blood RH factor prior to performance of an ob- range complications and their effect on subsequent preg- stetrical procedure, including an abortion (§ 205.730(a)(1)) nancies." 462 U.S. at 487-88, 103 S.Ct. at 2523 (emphasis and hemoglobin and hematocrit and urine analysis ex- in original). Further, the information and knowledge gained aminations before performing an abortion, as well as pro- from the aggregated pathological testing and reports will cedures performed with general anesthesia or local anes- aid other women in the future. The requirement for a patho- thesia with sedation (§ 205.520(b)). At trial, Dr. Ragsdale logical report on any abnormalities in the tissue in ques- admitted that he had no disagreement with the need to tion is proper and constitutional in light of Ashcroft. perform appropriate laboratory tests. Thus, these provi- Section 205.760 of the ASTC regulations requires a re- sions in no way impinge upon a woman's decision to have port, on forms provided by the Department of Public an abortion because they merely state the standard med- Health, of each abortion procedure performed in an ASTC ical tests necessary to perform a safe abortion. In this within ten days following the month in which the abor- respect, they are no more offensive or intrusive on a tion was performed. If the doctor who performed the woman's right to an abortion than $ 205.710 which states: abortion later discovers a complication, such as hemor- "Abortions shall be provided to the public with the same rhaging, then he or she is required to file a supplemen- tal report. 20 In Planned Parenthood v. Danforth, 428 U.S. 52, 96 S.Ct. at 2831 (1975), the Supreme Court stated: 20 continued partment of Public Health. This data is to include the number and type of procedures performed and complications reported, the 20 In a companion regulation which is not abortion specific, § 205.620 number of patients requiring transfer to a hospital due to com- requires each ASTC to submit annual statistical data to the De- plications, the number of patients returning for followup contact, (Footnote continued on following page) and the number of deaths. App. 76 App. 77 standards of safety, effectiveness, and regard for pa- "The decision to abort is an important, and often stressful tients['] rights as any other health service." As Dr. Rags- one, and it is desirable and imperative that it be made dale's counsel concededly stated at trial, "Obviously, Dr. with full knowledge of its nature and consequences." Dan- Ragsdale agrees with that statement. We agree with that, forth, 428 U.S. at 67, 96 S.Ct. at 2840. See also City of and I suspect everyone in this room agrees with that Akron, 462 U.S. at 442-43, 103 S.Ct. at 2499.22 This is statement." Finally, I do not agree with the majority's conclusion 21 continued that the counseling requirements of § 205.730(b) run afoul A Yes. of the Supreme Court's ruling in Thornburgh v. American Q well, why do you provide [counseling], Dr. Hern? College of Obstetricians, 476 U.S. 747, 106 S.Ct. 2169 (1986). A Well, I believe that it is important for each patient to In Thornburgh the Court found unconstitutional provisions have not only a good understanding of the procedure that of the state statute that required a woman to be informed she is going to be having and how she got pregnant [?!] of fetal characteristics, the availability of financial assist- and what the methods are for her, I mean, for her to be ance, detrimental physical and psychological effects, and permitted or to permit her to avoid unwanted pregnan- all particular medical risks. Id. at 759-765, 106 S.Ct. at cies in the future. 2178-81. But the Court held that this detailed information Q Well, do you say the same things to every patient, Dr. exceeded the state's interest in describing the general sub- Hern? Do you give the same counseling? ject matter relevant to informed consent because it "is not A In general, yes. Although it really depends upon the in- medical information that is always relevant to the woman's dividual patient as to how much we give as to that but I also think that-how much emphasis we give and as to decision and it may serve only to confuse and punish her what, but, as I say, it is also important for the patient and to heighten her anxiety contrary to accepted medical to have an opportunity to express her feelings about the practice." Id. at 762, 106 S.Ct. at 2179. pregnancy and about the abortion and, perhaps, the rela- tionship in which it occurred. In contrast, the counseling requirements of § 205.730(b) Q Would you always, Dr. Hern, for example, include in include a description of the procedure to be performed, your discussion with the woman a discussion of the alter- an explanation of risks and possible complications, and a natives for dealing with pregnancy? discussion of alternatives. These requirements are signifi- A Yes. And depending also to some extent on the patient's cantly less instrusive than the ones invalidated in Thorn- interest in this subject. Some patients absolutely refuse burgh, and the record establishes through Dr. Hern's to discuss alternatives; they come in and they have their testimony as an expert witness, that counseling is an in- minds absolutely made up about what they want to do dispensable part of a thorough pre-operative evaluation and they are impatient to get on with the process and and preparation of a patient for an abortion procedure. they really do not wish to spend a great deal of time talk- ing about, for example, adoption." Dr. Hern testified that appropriate counseling should in- clude a discussion of the alternatives for dealing with preg- (Emphasis added). nancy.21 As the Supreme Court has repeatedly recognized, 22 According to the majority, the counseling requirement and in particular "the requirement of a 'discussion of alternatives' is un- constitutional." The majority relied on Ragsdale's testimony to the 21 Dr. Hern, the court-qualified expert, testified as follows: effect that discussions of alternatives might not be appropriate. "Q Now, you testified earlier that you do provide counseling Ragsdale speculated that it would be inappropriate to inform a in your facility, is that right, doctor? woman of alternatives if her continuing health was dependent on (Footnote continued on following page) (Footnote continued on following page) App. 78 App. 79 true since "[a]bortion is inherently different from other the bill) places on informed consent. The Illinois counsel- medical procedures, because no other procedure involves ing regulations merely require that a woman planning to the purposeful termination of potential life." Harris v. terminate her pregnancy do SO knowingly; Roe does not McRae, 448 U.S. 297, 325, 100 S.Ct. 2671, 2692 (1980). hold to the contrary. However, § 205.730(b)(2)(D) requires Thus, I emphasized in Zbaraz v. Hartigan, 763 F.2d at that "[c]ounselors shall have no financial interest in the 1549-50 (Coffey, J., dissenting): patient's decision" and appears to interfere with the "There are severe psychological and emotional physician-patient relationship and should be severed and stresses involved not only before and during the abor- enjoined. Thus, I do not believe that the counseling re- tion procedure, but for days, months and even years quirements of § 205.730(b), except (2)(D), are improper and following the procedure For many individuals would uphold their validity. the abortion decision raises questions that are often influenced by sincere, deep-rooted religious IV beliefs, moral principles, and convictions. [J]ust In conclusion, I am convinced that individual states have as in any surgical procedure, [a woman] is entitled the obligation, the duty, and the power to license medical to an explanation of the reasonable alternatives to ASTC facilities where semi-complex (minor) surgical proce- abortion. dures, including first-trimester abortions, are performed I am firmly convinced that Illinois can require a counselor as a valid exercise of a state's interest in protecting health to provide a woman with a description of the procedure and ensuring maximum safety for the patients. Determin- to be performed, an explanation of risks and possible com- ing where to strike the balance between competing inter- plications, and a discussion of alternatives so that the ests is a matter for the legislature, not for the court. The woman can make a responsible enlightened choice in light Constitution wisely vests the legislative branch of the of the fact that no other medical procedure "involves the government with the power and authority to enact laws, purposeful termination of a potential life." Harris v. McRae, for the legislature is better equipped to carry out that 448 U.S. at 325, 100 S.Ct. at 2692. Further, the majority's task in that interested parties, such as state and local rejection of the counseling requirements ignores the recent governmental representatives, medical experts, etc., are trend in medicine which encourages patients to seek sec- able to present their respective positions before the legis- ond opinions before undergoing surgical procedures. In lative body in a more open, unrestricted, informal forum. some instances insurance companies have even required Thereafter, the myriad of questions and problems, as well a second opinion with respect to non-emergency surgeries as their possible solutions, are brought before the entire before providing coverage. These developments reflect the legislative branch of government and are subject to the importance the medical profession (as well as those footing scrutiny of public hearing and debate. When dealing with the complex and ever-changing question of how to pro- vide the best health care at a reasonable cost to its citi- 22 continued zens, the factfinding and policy making capabilities of a her undergoing a medically necessary abortion. Obviously, in this court of law are far more limited and confined due to the situation a "discussion of alternatives" is inappropriate simply because there are no alternatives. The majority's interpretation very nature of a court of law. A truly independent judi- of the Illinois regulations would lead to absurd results. It is clear ciary must always exercise its powers of review and deci- that a discussion of alternatives is required only when alternatives sion making with discretion and reservation, recognizing in fact exist. that we are not competent to make social and economic App. 80 App. 81 policy decisions, and giving due deference to the legisla- APPENDIX tive branch of government. Our judicial responsibility ob- ligates us to declare an act by another governmental unit to be void only if we believe the enacted law is contrary TITLE 77 ILLINOIS ADMINISTRATIVE CODE: to the Constitution. After reviewing the ASTCA and the PUBLIC HEALTH challenged provisions of the IHFPA, I am convinced that the expressed will of the people as enacted in these Illi- CHAPTER 1: DEPARTMENT OF PUBLIC HEALTH nois statutes is not contrary to the principles of the Con- SUBCHAPTER b: HOSPITALS AND AMBULATORY stitution; thus, I would not interfere with this well- CARE FACILITIES reasoned judgment of the Illinois legislature, a coequal PART 205 branch of the government. Surely the Illinois legislature MINIMUM STANDARDS, RULES AND REGULATIONS is entitled to require that all surgical procedures, including FOR THE LICENSURE OF first-trimester abortions, are performed "under conditions AMBULATORY SURGICAL TREATMENT CENTERS. ensuring maximum safety for the woman [as well as the man]." Connecticut v. Menillo, 423 U.S. at 11, 96 S.Ct. at 171. Moreover, other than § 16(1) of the MPA, its companion SUBPART A: GENERAL clause in the ASTCA, and § 205.730(b)(2)(D), I believe that Section 205.120 Licensure the statutes and regulations in question do not place a a) An application for license shall be made to the De- burden on a woman's decision to terminate her pregnancy partment on forms provided by it. This application in the first trimester. Further, if one is able to find a shall contain the information required under the Act burden, it is certainly below the level of de minimis. Last- and this Part. The application shall be submitted ly, the regulations reflect common, accepted and approved not less than sixty (60) days prior to the date of standards of medical practice and procedure and are de- intended operation. signed to enhance the safety of Illinois' citizens, an im- b) The application shall include but not be limited to portant state interest. For the foregoing reasons, I would the following information: reverse the order of the district court. 1) the name(s) and address(es) of person(s) who own and/or operate the facility and the name under which they do business. A corporation shall submit: A) a copy of its certificate of incorporation, B) list of the title, name, and address of each of its corporate officers, C) list of the name and address of each of its shareholders holding more than 5%, of the shares. 2) location of the facility. 3) description of the facility including but not limited to interviewing, examination, surgical, and recovery room facilities. App. 82 App. 83 4) schematic architectural plans. E) Every facility licensed under this Act, and 5) documentation of compliance with all applicable any premises proposed to be conducted as building, utility and Safety Codes. a facility by an applicant for a license shall 6) description of services to be provided by the be open during its regular business hours facility including a list of surgical procedures to an inspection authorized in writing by to be performed. the Director. No notice need be given to 7) list of all personnel including their name, ad- any person prior to any inspection, dress, position, qualifications and licensure. F) Any corporation operating an Ambulatory 8) All applications shall be signed by the applicant Surgical Treatment Center devoted pri- and the application shall include a verification marily to providing facilities for abortion form acknowledging the application to be true must have a physician who is licensed to and complete and certifying that the applicant practice medicine in all of its branches and has knowledge of and understands the action is actively engaged in the practice of medi- required to comply with the Act and licensing cine at the center, on the Board of Direc- requirements. The form shall be verified by a tors as a condition to licensure of the center. notary public. The forms shall be accompanied e) Only those facilities, services, programs and pro- by a license fee of $500. cedures included in the application shall be licensed. 9) As a condition of the issuance or renewal of the A new application is required for the following: license of any Ambulatory Surgical Treatment 1) change in ownership, Center: 2) change in location, A) The applicant shall file a statement of owner- 3) remodeling of facility S0 as to change the inter- ship. The applicant shall agree to update viewing, examination, surgical or recovery room the information required in the statement space or number, of ownership every 6 months from the in- 4) addition of services or programs. itial date of filing, AGENCY NOTE: The addition of new spe- B) Each license shall file an attested financial cialty services, for example, podiatry or ob- statement with the Department by July 1, stetrics/gynecology, may require changes in 1980 and at times thereafter as required, consulting committee, procedures and/or C) Financial statements shall be filed annual- staffing. Therefore, the Department finds ly on or before April 1, of each year for that a new license is needed. the previous calendar year, or within three d) The license shall be valid for one (1) year, unless (3) months after the close of the fiscal sooner suspended or revoked, shall be renewable period of the licensee, annually upon approval by the Department and pay- D) A financial statement shall be filed with ment of a license fee of $300. Each license shall be the Department on forms provided by the issued only for the premises and persons named in Department or on annual financial state- the application and shall not be transferable or as- ments prepared on forms used by the ap- signable. The licenses shall be posted in a conspicu- plicant. At minimum, they shall include de- ous place on the licensed premises. A placard or tailed balance sheets, statements of income registry of all physicians on staff in the facility shall and statements of expense, be centrally located and available for inspection to App. 84 App. 85 any interested persons. The renewal application medical gases. The current edition of the National shall be on forms provided by the Department and Fire Protection Association Code (Standard No. 56a) shall be submitted to it not less than 30 days prior shall be used as the standard. to the expiration date. d) There shall be written procedures to assure the e) The facility shall give written notice to the Depart- safety in storage and use of all narcotics and medi- ment within seven (7) days of any of the following: cations in accordance with state and federal law. 1) change of administrative staff, (Source: Amended at 3 III. Reg. 30, p. 371, effective 2) change of medical director, July 23, 1979) 3) change of staff physicians, * * * 4) change of supervising nurse, SUBPART E: GENERAL PATIENT CARE 5) addition or deletion of surgical procedures per- formed, Section 205.520 Preoperative Care 6) in the case of a corporation change in any share- a) Where medical evaluation, examination, and referral holders equity involving 5% or more interest. are made from a private physician's office, hospital, (Source: Amended at 6 III. Reg. 6220, effective May 17, or clinic, pertinent records thereof shall be avail- 1982) able and made part of the patient's clinical record * * * at the time the patient is registered and admitted to the ambulatory surgical treatment center. SUBPART D: EQUIPMENT, SUPPLIES, b) A complete medical history shall be obtained and AND FACILITY MAINTENANCE the physical examination shall be complete. A hemo- Section 205.410 Equipment globin or hematocrit and examination of the urine Equipment shall be in good working order and shall be for sugar, protein, and acetone shall be performed available in numbers sufficient to provide good patient by a qualified laboratory technician prior to the care based on the procedures to be performed in the facil- following procedures: ity. 1) those performed with general anesthesia, a) There shall be monitoring equipment, suction ap- 2) those performed with local anesthesia with se- paratus, oxygen and related items available within dation, the surgical and postoperative recovery area. Cardiac 3) those performed to terminate pregnancy. pulmonary resuscitation equipment shall be avail- c) A written statement indicating informed consent able in all facilities. and a signed authorization by the patient for the b) There shall be written procedures governing the performance of the specific surgical procedure shall care, use, sterilization, storage and disposal of all be procured and made part of the patient's clinical materials to insure that an adequate supply of record. sterile equipment is available for each procedure. d) Surgical procedures shall not be performed on pa- The section on "Sterilization and Disinfection" from tient's having medical, surgical, or psychiatric con- Infection Control in the Hospital, most recent edi- ditions or complications as specified by the consult- tion, American Hospital Association, shall be used ing committee in the facility's written policies. as the guideline. (Source: Amended at 6 Ill. Reg. 10974, effective August e) There shall be written procedures to assure safety 30, 1982) in storage and use of inhalation anesthetics and App. 86 App. 87 Section 205.530 Operative Care AGENCY NOTE: Procedures involving the a) Surgical procedures shall be performed only by a pregnant uterus are subject to particular qualified physician, dentist or podiatrist within the complications and postoperative care re- limits of his/her defined specific practice privileges. quires a special knowledge on the part of b) A qualified anesthesiologist, a dental anesthesiolo- nursing staff. gist or a certified registered nurse anesthetist, (Source: Amended at 3 Ill. Reg. 30, p. 371, effective medically directed by a licensed physician who ad- July 23, 1979) ministers or directs the administration of anesthesia Section 205.730 General Patient Care in an Illinois licensed hospital, shall be present for a) Examination the administration of anesthetics and recovery of 1) Prior to obstetrical procedures blood Rh factor patients when any general or major regional anes- shall be determined by a qualified laboratory thetic is used. technician for every patient. c) All tissues removed during surgery shall be exam- 2) The physician performing an abortion procedure ined by a consulting pathologist and all x-rays shall shall establish the diagnosis of pregnancy by ap- be read by a consulting radiologist who shall pro- propriate clinical evaluation and testing prior vide a written report of his/her examination to the to performing an abortion procedure. attending physician. A copy of this report shall be 3) Time shall be allowed between the initial exam- filed in the patient's clinical record within seven (7) ination and termination of pregnancy to permit (Source: days. Amended at 6 III. Reg. 13337, effective October the reporting to and reviewing of all laboratory tests with the patient by the facility physician. 20, 1982) b) Counseling * * * 1) Counseling shall be provided following disclo- SUBPART G: ADDITIONAL REQUIREMENTS sure to the patient of the diagnosis of preg- FOR FACILITIES IN WHICH nancy, and prior to performance of any surgical OBSTETRICAL/GYNECOLOGICAL PROCEDURES procedure. It shall be done individually and in ARE PERFORMED. a room designated for such use which shall not be the procedure room. Section 205.710 Abortions 2) All facilities shall provide orientation training Abortions shall be provided to the public with the same for counselors and insure that each counselor standards of safety, effectiveness, and regard for patients is qualified to: rights as any other health service. A) Counseling shall be done by a person quali- (Source: Amended at 3 III. Reg. 30, p. 371, effective fied to: July 23, 1979) i) discuss alternatives for dealing with Section 205.720 Personnel an unwanted pregnancy; At least one registered professional nurse with postgrad- ii) describe the procedures used in the uate education or experience in obstetrical or gynecologi- facility; cal nursing shall supervise and direct the nursing person- iii) explain the risks and possible compli- nel and care of patients having obstetrical procedures. cations of each procedure; iv) provide contraception information. App. 88 App. 89 B) Demonstration of such counseling qualifica- Section 205.750 Postoperative Requirements tions shall be required by the Department. a) Each obstetrical/gynecological service shall provide C) Documentation of orientation training shall Rh factor sensitization prophylaxis to all Rh nega- be required by the Department. tive patients according to standard medical pro- D) Counselors shall have no financial interest cedures. in the patient's decision. b) Information on availability of family planning ser- 3) Counseling shall include a discussion of alter- vices shall be provided, when desired by the pa- natives, description of the procedure to be per- tient. When, in the physician's opinion, it is in the formed, explanation of risks and possible compli- best interest of the patient and with the patient's cations. Contraceptive information may be pro- consent, family planning services may be initiated vided postoperatively. Group counseling may be prior to the discharge of the patient. provided in addition to individual counseling. (Source: Amended at 5 Ill. Reg. 12756, effective No- The patient's clinical record shall include docu- vember 4, 1981) mentation of the counseling received. AGENCY NOTE: In the opinion of the Am- Section 205.760 Reports bulatory Surgical Treatment Center Li- a) A report of each abortion procedure performed in an ambulatory surgical treatment center shall be censing Board, the patient should make a made to the Department on forms provided by it. decision concerning the procedure in an at- These reports shall be submitted not later than ten mosphere free from coercion. Consequent- ly, the Board believes this is best ac- (10) days following the month in which the abor- complished in a room separate and apart tion was performed. Reports shall be submitted on from the procedure room. The Board be- procedures performed whether or not the patient lieves that it is difficult to reach a truly was pregnant. voluntary decision while the patient is un- b) Reports shall not be filled out in such a manner or at such a time as to avoid accurate reporting dressed and on the procedure table. (Source: Amended at 5 Ill. Reg. 12756, effective No- of complications. c) If the facility becomes aware of a complication vember 4, 1981) following the submission of the original report, then Section 205.740 Preoperative Requirements a supplemental report shall be submitted to the De- Abortions may be performed in a ambulatory surgical partment. treatment center on only those patients with gestation up (Source: Amended at 3 III. Reg. 30, p. 371, effective to and including 12 weeks commencing with ovulation July 23, 1979) rather than computed on the basis of the menstrual cycle, * * * as determined by the physician, if the patient's medical SUBPART I: BUILDING DESIGN, CONSTRUCTION condition permits. Abortions shall not be performed in an STANDARDS, AND PHYSICAL REQUIREMENTS Ambulatory Surgical Treatment Center on those patients whose gestation exceeds 12 weeks. Section 205.1320 General Considerations (Source: Amended at 3 Ill. Reg. 30, p. 371, effective a) Location July 23, 1979) This facility shall be indentifiably separate from other facilities and functions. App. 90 App. 91 b) Narrative Program permit at least 2'-6" clearance at each side and The sponsor for each project shall provide a nar- at both ends of the examination table. rative program of functions for the facility which 2) A lavatory or sink equipped for handwashing contains space requirements, staffing patterns, de- with knee or foot control shall be provided. partmental relationships and other basic informa- 3) A counter or shelf space for writing shall be tion relating to the fulfillment of the institution's provided. objectives. This may be a general or detailed de- b) Procedure room(s) scription of each function to be performed, space 1) Provide at least one procedure room with a needed for these functions, hours of operation, num- minimum clear area of 250 square feet and a ber of staff or other occupants of the various spaces, minimum dimension of 14 feet, exclusive of fixed types of equipment required, interrelationship of and movable cabinets and shelves. Any other various functions and spaces, and description of procedure rooms shall not be less than 120 those services necessary for the complete function- square feet with a minimum dimension of 10 ing of the facility but which are available elsewhere feet. in the community and, therefore, need not be dupli- 2) Provide a communication system connecting cated in this facility. Explain the type of surgery with the control station. or procedures, the volume of work, the number of 3) Provide special features such as x-ray film il- doctors, etc. luminators, and storage space as required by e) Size the program. The extent (number and types) of the diagnostic, c) Recovery room(s) clinical, and administrative facilities to be provided 1) Room(s) for post-anesthesia recovery for surgi- shall be determined by the services contemplated cal patients shall be provided. and the estimated patient load as described in the 2) Recovery room(s) shall contain a minimum of narrative program. 100 square feet of usable floor space for single d) Provisions for the Handicapped bed occupancy and at least 80 square feet per The design shall provide for accessibility to the phy- bed for multiple bed occupancy, SO arranged sically handicapped (public, staff, and patients). that there will be at least 3 feet between beds e) Privacy for Patient and 4 feet of clear space at the foot of each The design of the facility shall provide for the bed. privacy and dignity of the patient during interview, 3) This room(s) shall contain a drug distribution examination, and treatment. station, handwashing facility, charting facilities, (Source: Amended at 6 III. Reg. 6220, effective May 17, nurses' station, and storage space for supplies 1982) and equipment. 4) Provide a toilet which is accessible to the recov- Section 205.1360 Clinical Facilities ery room, without having to leave the recovery a) Examination room(s) room to reach it. The water closet shall be 1) Each examination room(s) shall have a minimum equipped with a gray diverter valve. clear floor area of 80 square feet, and a mini- 5) A separate supervised room may be provided mum dimension of 8 feet, excluding such spaces for use by patients who are able to leave the as vestibule, toilet, closet, and work counter recovery (post-anesthesia) room but need addi- (whether fixed or movable). Arrangements shall App. 92 App. 93 tional time for all vital signs to be stabilized f) Fluid waste disposal facilities shall be convenient- to the point where the patient may leave the ly located with respect to the general procedure facility. This room shall be equipped with re- rooms. clining or lounge type chairs for patients and g) shall contain a minimum of 50 square feet of 1) A clean workroom or a clean supply room is usable floor space for each patient to be accom- required when clean materials are assembled modated at any one time. within the surgical suite prior to use. A clean 6) These recovery rooms may be combined, if de- workroom shall contain a work counter, sink sired. equipped for handwashing, and space for clean 7) Provide a minimum of four recovery beds or and sterile supplies. A clean supply room shall lounge chairs for each procedure room. At least be provided when the narrative program de- one of the four must be a bed, and the other fines a system for the storage and distribution three may be lounge chairs or beds. of clean and sterile supplies which would not (Source: Amended at 6 III. Reg. 6220, effective May 17, require the use of a clean workroom. 1982) 2) An autoclave shall be incorporated into the Section 205.1370 Support Service Areas clean workroom. a) A control station shall be located to permit visual h) Anesthesia storage facilities shall be provided. Flam- surveillance of all traffic which enters the operating mable anesthetics are prohibited. suite. i) Medical gas supply storage with space for reserve b) Provide sterilizing facility(ies) with high speed auto- nitrous oxide and oxygen cylinders shall be pro- clave(s) conveniently located to serve all procedure vided, with all tanks properly secured. rooms. Approved alternate provisions may be made j) Storage area for equipment and supplies used in for replacement of sterile instruments during sur- surgical suite shall be provided. gery. k) Staff and personnel facilities shall be provided for c) A drug distribution station shall be provided for male and female personnel (orderlies, technicians, storage and preparation of medication to be admin- nurses, and doctors) working within the surgical istered to patients. suite. The areas shall contain lounge, lockers, toilets, d) Scrub stations with knee or foot or elbow actuated lavatories equipped for handwashing, and space for faucets shall be provided near the entrances to the changing clothing. These areas shall be arranged to procedure rooms. Scrub facilities shall be arranged provide a one-way traffic pattern so that person- to minimize splatter on nearby personnel or supply nel entering from outside the surgical suite can carts. change, gown, and move directly into the surgical e) A soiled workroom for the exclusive use of the sur- suite. Space for removal of scrub suits and foot gical suite staff shall be provided. The soiled work- covers shall be designed so that personnel using it room shall contain a work counter, sink equipped will avoid physical contact with clean personnel. for handwashing, waste receptacle, and linen recep- 1) Provide change areas where patients can change tacle. This room may be used for cleaning anesthe- from street clothing into hospital gowns in privacy, sia equipment. and be prepared for surgery. This shall include lockers, toilets, clothing change or gowning area(s), and space for the administration of medications. App. 94 App. 95 m) Stretcher storage area shall be out of direct line of traffic. b) The facility or section shall have at least two exits n) Janitor's closet containing a floor receptor or ser- remote from each other. Other details relating to exits and fire safety shall be in accordance with vice sink, and storage space for housekeeping sup- Section 13 (Business Occupancy) of the latest edi- plies and equipment shall be provided exclusively for the surgical suite. tion of NFPA Standard 101 and the requirements outlined herein. These Standards govern where dif- (Source: 1982) Amended at 6 III. Reg. 6220, effective May 17, ferent from the code. c) Items such as drinking fountains, telephone booths, Section 205.1380 Diagnostic Facilities vending machines, and portable equipment shall be If the pre-admission evaluation tests are to be performed located SO as not to restrict corridor traffic or re- within the facility, the following services shall be provided. duce the corridor width below the required mini- a) Radiographic suite, if provided, shall contain the mum. following: d) All doors to toilets which may be used by patients 1) film processing area shall be equipped with hardware which will permit 2) viewing and administration area access in an emergency. 3) film storage facilities e) The minimum width of doors for patient access to 4) toilet room with handwashing facilities, direct- examination and treatment rooms shall be 3'-0". ly accessible from each fluoroscopy room with- f) The minimum width of doors to rooms needing ac- out entering the general corridor area. cess for stretchers (procedure rooms, recovery) shall 5) dressing area with convenient access to toilets. be 3'-8". b) Laboratory suite shall contain the following mini- g) Doors on all openings between corridors and rooms mum facilities: or spaces subject to occupancy, except elevator 1) Laboratory work counter with sink and vacuum, doors, shall be swing type. and electric services. h) Doors, except doors to spaces such as small closets 2) Lavatory or counter sink equipped for hand- which are not subject to occupancy, shall not swing washing. into corridors in a manner that might obstruct traf- 3) Storage cabinet or closet. fic flow or reduce the required corridor width. 4) Specimen collection facilities equipped with a i) Doors, sidelights, borrowed lights, and windows in toilet and lavatory. which the glazing extends downs to within 18 inches 5) Blood collection facilities shall have space for of the floor (thereby creating possibility of acciden- a chair and work counter. tal breakage by pedestrian traffic) shall be glazed (Source: Amended at 6 III. Reg. 6220, effective May 17, with safety glass, wire glass, or plastic glazing ma- 1982) terial that will resist breaking and will not create * * dangerous cutting edges when broken in accordance Section 205.1400 Details and Finishes with the State of Illinois Safety Glazing Materials a) Minimum public corridor width shall be 5'-0", except Act (Ill. Rev. Stat. 1981, ch. 111½, par. 3101 et those corridors where patients are transported in seq.). Similar materials shall be used in wall open- stretchers or carts shall be 8'-0". ings unless required otherwise for fire safety. App. 96 App. 97 j) Thresholds and expansion joint covers shall be made o) Flammable Anesthetics are prohibited. flush with the floor surface to facilitate use of p) Cubicle curtains and draperies shall be noncombus- wheelchairs and carts. tible or rendered flame retardant and shall pass k) Air dryers, or paper towel dispensers and waste both the large and small scale tests of NFPA Stan- receptacles shall be provided at all handwashing dard 701. fixtures. q) Interior finish of walls and ceilings of all exit ways, 1) Where labeled fire doors are required, these shall storage rooms, and areas of unusual fire hazard be certified by an independent testing laboratory shall have a flame spread rating of not more than as meeting the construction requirements equal to those for fire doors in National Fire Protection As- r) 25. Floor finish materials shall have a flame spread sociation (NFPA) Standard 80. Reference to a labeled rating of not more than 75. If a separate underlay- fire door shall be construed to include labeled frame ment is used with any floor finish material, the and hardware. flame spread test assembly shall include the under- m) Radiation protection requirements of X-ray and gamma ray installations shall conform to the re- s) layment. All interior finish materials shall have smoke de- quirements of the Department of Nuclear Safety veloped rating of 450 or less. The use of materials Rules for Protection Against Radiation (32 III. Adm. known to produce large amounts of toxic gases shall Code, Subchapter b) and should follow guidelines be avoided. of NCRP reports #33 dated February 1968, and #49 t) Floor materials shall be easily cleanable and have dated September 1976. Provisions shall be made for wear resistance appropriate for the location involved. testing and completed installation before use, and 1) In all areas frequently subject to wet cleaning all defects must be corrected before use. methods, floor materials shall not be physical- n) The minimum ceiling height shall be 8'-0", with the ly affected by germicidal and cleaning solutions. following exceptions: 2) Floors that are subject to traffic while wet, 1) Boiler rooms, if provided, shall have ceiling shall have a nonslip surface. clearance not less than 2'-6" above the main u) Wall finishes shall be washable and in the immedi- boiler header and connecting piping. ate area of plumbing fixtures, shall be smooth and 2) Radiographic and other rooms containing ceil- moisture resistant. ing-mounted equipment and including those v) Floor and wall penetrations by pipes, ducts, and with ceiling-mounted surgical light fictures shall conduits shall be tightly sealed to minimize entry have height required to accommodate the equip- of rodents and insects. Joints of structural elements ment and/or fixture. shall be similarly sealed. 3); Ceilings in corridors, storage rooms, toilet rooms, w) Ceilings shall be cleanable and those in sensitive and other minor rooms may be not less than areas such as surgical rooms shall be readily wash- 7'-8". able and without crevices that can retain dirt par- 4) Suspended tracks, rails, and pipes located in ticles. These sensitive areas shall have a finished path of normal traffic shall be not less than 6'- ceiling, covering all overhead ductwork and piping. 8" above the floor. x) Finished ceilings may be omitted in mechanical and equipment spaces, shops, general storage areas, and App. 98 App. 99 similar spaces, unless required for fire-resistive pur- shall be removed near the floor level. At least two poses. exhaust outlets shall be used in each procedure y) Acoustical ceilings are recommended in corridors, multipurpose rooms, and waiting areas. h) room. All central ventilation or air conditioning systems (Source: 1982) Amended at 6 III. Reg. 6220, effective May 17, shall be equipped with filters having efficiencies not less than those specified in the following table: * * * SUBPART J: MECHANICAL FILTER EFFICIENCIES FOR CENTRAL VENTILATION AND AIR CONDITIONING SYSTEMS IN Section 205.1540 Air Conditioning, Heating and AMBULATORY SURGICAL TREATMENT FACILITIES Ventilating Systems Filter a) The systems shall be designed to provide the com- Efficiencies fort temperatures and humidities as recommended Minimum (Percent) by ASHRAE Standards. Number of Filter Bed Filter Bed b) Air handling systems shall conform to "Installation 90A-1976. of Air Conditioning and Ventilating Systems," NFPA Area Designation Filter Beds No. 1 No. 2 Procedure and c) For spaces not exceeding 25,000 cubic feet in volume, Recovery Rooms 2 25 90 25 - heating, air conditioning, and ventilating systems All Other Areas 1 shall conform to "Standard for the Installation of i) All filter efficiencies shall be average atmospheric Warm Air Heating and Air Conditioning Systems, dust spot efficiencies tested in accordance with the NFPA 90-B, 1973, except return ducts shall be con- American Society of Refrigeration and Heating, Air structed of material equal to that specified for sup- Conditioning Engineers (ASHRAE) Standards 52-68. ply ducts, Chap. 2, paragraph 1.1., Duct Materials. j) For systems serving procedure and recovery rooms, d) Outdoor air intakes shall be located as far as prac- filter bed No. 1 shall be located upstream of the tical but not less than 15 feet from exhaust outlets conditioning equipment and filter bed No. 2 shall of ventilation systems, combustion equipment stacks, be located downstream of the supply fan and condi- medical-surgical vacuum systems, plumbing vent tioning equipment including humidifiers. stacks or from areas which may collect vehicular k) Filter frames shall be durable and shall provide an exhaust and other noxious fumes. airtight fit with the enclosing duct work. All joints e) All ventilation air outlets and inlets shall conform between filter segments and enclosing duct work to NFPA 90A-Chapter 2, paragraph 3.2. Location shall be gasketed or sealed to provide a positive of Outlets and Inlets. seal against air leakage. f) The ventilation systems shall be designed and bal- 1) A manometer shall be installed across each filter anced to provide the ventilation and pressure rela- bed serving procedure and recovery rooms. tionships as shown in Table A. m) Fire and smoke dampers shall be constructed, lo- g) The ventilation air supplied to the procedure rooms cated and installed in accordance with the require- shall be delivered at or near the ceiling of the area ments of NFPA 90A. served, and all exhaust or return air from the area App. 100 App. 101 n) All systems, regardless of size, which serve more Section 205. TABLE A General Pressure Relationships and Ven- than one smoke or fire zone, shall be equipped with tilation Rates of Ambulatory Surgery Area smoke detectors to shut down fans automatically as Minimum specified in paragraph 4-3.1 of NFPA 90A. Pressure Total Air All Air o) The ventilation system for anesthesia storage rooms Within Relation- Changes per Exhausted shall conform to the requirements of "Standard for Area ship Hour Directly Inhalation Anesthetics" NFPA 56A, including the Room Units to Adjacent Supplied to Recircu- gravity option ventilation system. Designation Areas to Room Outdoors lated p) Boiler rooms shall be provided with sufficient out- door air to maintain combustion rates of equipment Procedure Room + 15 Optional No and limit temperatures in working stations to 97° F Examination Room 0 6 Optional Optional Effective Temperature as defined by ASHRAE Recovery Room + 6 Optional Optional Handbook of Fundamentals. Medication Area + 4 Optional Optional q) Rooms containing heat-producing equipment, such X-Ray Room 0 6 Optional Optional as boiler rooms and heater rooms, shall be insulated Soiled Workroom or Soiled Holding - 10 Yes No and ventilated to prevent any floor surface above Clean Workroom from exceeding a temperature of 100° F. or Clean Holding + 4 Optional Optional (Source: Amended at 6 III. Reg. 6220, effective May 17, Darkroom - 10 Yes No 1982) Toilet Room - 10 Yes No Janitors' Closet - 10 Yes No Sterilizer Equip. Rm. - 10 Yes No Linen and Trash Rm. - 1- Yes No Laboratory - 6 Optional Optional Soiled Linen Storage - 10 Yes No Clean Linen Storage + 2 Optional Optional Anesthesia Storage 0 8 Yes No Central Services Area Soiled Area - 6 Yes No Clean Area + 4 Optional Optional Equipment Storage 0 2 Optional Optional + = Positive - = Negative 0 = Equal (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) App. 102 App. 103 APPENDIX B APPENDIX C JUDGMENT - ORAL ARGUMENT UNITED STATES COURT OF APPEALS UNITED STATES COURT OF APPEALS For the Seventh Circuit For the Seventh Circuit Chicago, Illinois 60604 Chicago, Illinois 60604 March 10, 1988. April 13, 1988. Before Before Hon. WILLIAM J. BAUER, Chief Judge Hon. WILLIAM J. BAUER, Chief Judge Hon. JOHN L. COFFEY, Circuit Judge Hon. JOHN L. COFFEY, Circuit Judge Hon. JESSE E. ESCHBACH, Senior Circuit Judge Hon. JESSE E. ESCHBACH, Senior Circuit Judge RICHARD M. RAGSDALE, M.D., et al., RICHARD M. RAGSDALE, et al., Plaintiffs-Appellees, No. 85-3242 Plaintiffs-Appellees, VS. No. 85-3242 V. BERNARD J. TURNOCK, Director of Illinois Department of State of Illinois, GARY L. CLAYTON, Director of the Illi- Public Health, NEIL F. HARTIGAN, Attorney General, BERNARD J. TURNOCK, Director of the Illinois Department of Public Health, et al., nois Department of Registration and Education, Defendants-Appellants. Defendants-Appellants. Appeal from the United States District Court Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. for the Northern District of Illinois, Eastern Division. No. 85-C-6011-John A. Nordberg, Judge. No. 85-C-G011-John A. Nordberg, Judge. This cause was heard on the record from the United States District Court for the Northern District of Illinois, ORDER Eastern Division, and was argued by counsel. On consideration whereof, IT IS ORDERED AND AD- The slip opinion in this matter issued on March 10, 1988, JUDGED by this Court that with the exception of the is amended as follows: tion of the injunction regarding the second trimester hos- por- In footnote 6 at pages 14-15, strike the present third pitalization requirement, which is VACATED AS MOOT, and fourth sentences and replace them with the follow- the preliminary injunction is AFFIRMED, in accordance ing sentence. with the opinion of this Court filed this date. Costs on appeal are assessed to appellants. App. 104 App. 105 However, the district court undertook a thorough APPENDIX D examination of the traditional factors governing the granting of preliminary relief, i.e., the lack of an adequate remedy at law, irreparable harm, UNITED STATES COURT OF APPEALS balance of harms, likelihood of success on the For the Seventh Circuit merits, and the public interest. Chicago, Illinois 60604 At page 3, line 10, strike the word "Providers" and substitute the word "Planning." AMENDED ORDER At page 5, line 13, strike the word "or" and substi- tute the word "for." August 16, 1988. At page 32, lines 5-7, strike the citation "Zbaraz v. Hartigan, 763 F.2d 1532, 1545 (7th Cir. 1985), appeal Before pending, No. 85-673" and substitute the following Hon. WILLIAM J. BAUER, Chief Judge "Zbaraz v. Hartigan, 763 F.2d 1532, 1545 (7th Cir. Hon. JOHN L. COFFEY, Circuit Judge 1985) aff'd U.S. , 108 S. Ct. 479 (1987)." Hon. JESSE E. ESCHBACH, Senior Circuit Judge RICHARD M. RAGSDALE, M.D., et al., Plaintiffs-Appellees, No. 85-3242 V. BERNARD J. TURNOCK, Director of Illinois Dept. of Public Health; NEIL F. HARTIGAN, Attorney General, State of Illinois; and GARY L. CLAYTON, Director of Illinois Dept. of Registration & Education, Defendants-Appellants. Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 85 C 6011-John A. Nordberg, Judge. ORDER On consideration of the petition for rehearing and sug- gestion for rehearing en bane filed by defendants-appel- App. 106 App. 107 lants and the answer filed by plaintiffs-appellees, a vote APPENDIX E was requested on the suggestion for a rehearing en bane. A majority of the members of the original panel voted to deny the petition for rehearing, and the suggestion of UNITED STATES COURT OF APPEALS rehearing en bane failed by an equally divided court.* For the Seventh Circuit Judges Wood, Posner, Coffey, Manion, and Kanne voted Chicago, Illinois 60604 to grant rehearing en banc. Accordingly, IT IS ORDERED that the aforesaid petition for rehear- August 12, 1988. ing and suggestion for rehearing en bane is DENIED. Before Hon. WILLIAM J. BAUER, Chief Judge Hon. JOHN L. COFFEY, Circuit Judge Hon. JESSE E. ESCHBACH, Senior Circuit Judge RICHARD M. RAGSDALE, M.D., et al., Plaintiffs-Appellees, No. 85-3242 V. BERNARD J. TURNOCK, Director of Illinois Dept. of Public Health; NEH. F. HARTIGAN, Attorney General, State of Illinois; and GARY L. CLAYTON, Director of Illinois Dept. of Registration & Education, Defendants-Appellants. Appeal from the United States District Court for the Northern District of Illinois, Eastern Division No. 85 C 6011-John A. Nordberg. Judge ORDER On consideration of the petition for rehearing and sug- * Judge Kenneth F. Ripple did not participate in the considera- gestion for rehearing en bane filed by defendants-appel- tion of the suggestion for rehearing en banc. App. 108 App. 109 lants and the answer filed by plaintiffs-appellees, a vote APPENDIX F was requested on the suggestion for a rehearing en banc. A majority of the judges in regular active service did not vote to rehear the case en banc, and a majority of the [Entered December 11, 1985] members of the original panel voted to deny the petition IN THE UNITED STATES DISTRICT COURT for rehearing. Accordingly, FOR THE NORTHERN DISTRICT OF ILLINOIS IT IS ORDERED that the aforesaid petition for rehear- EASTERN DIVISION ing and suggestion for rehearing en banc is DENIED. RICHARD M. RAGSDALE, M.D., et al., Plaintiffs, VS. BERNARD J. TURNOCK, et al., Defendants. No. 85 C 6011 - Judge Nordberg CLASS CERTIFICATION AND PRELIMINARY INJUNCTION ORDER This matter came to be heard upon plaintiffs' motion for class certification and upon plaintiff's motion for a pre- liminary injunction to enjoin and restrain defendants from enforcing § 16.1(a)-(e) of the Illinois Medical Practice Act, III. Rev. Stat. ch. 111, § 4433(a)-(e) ("the MPA"), the Illi- nois Ambulatory Surgical Treatment Center Act, Ill. Rev. Stat. ch. 111½, 9 157-8.1, et seq. ("the ASTC Act"), regula- tions promulgated under the ASTC Act, and the Illinois Health Facilities Planning Act, III. Rev. Stat. ch. 111½, § 1152-1168 ("the HFP Act"), against persons offering, performing, or desiring to offer or perform first or early second trimester abortions. The parties presented evi- dence and argument to the Court in hearings November 18-22 and November 26, 1985, and memoranda of law. Based upon the evidence, arguments and memoranda pre- Judge Kenneth F. Ripple did not participate in the consideration sented to the Court, on November 27, 1985 the Court of the suggestion for rehearing en banc. issued a Memorandum Opinion and Order granting plain- App. 108 App. 109 lants and the answer filed by plaintiffs-appellees, a vote APPENDIX F was requested on the suggestion for a rehearing en bane. A majority of the judges in regular active service did not vote to rehear the case en banc, and a majority of the [Entered December 11, 1985| members of the original panel voted to deny the petition IN THE UNITED STATES DISTRICT COURT for rehearing. Accordingly, FOR THE NORTHERN DISTRICT OF ILLINOIS IT IS ORDERED that the aforesaid petition for rehear- EASTERN DIVISION ing and suggestion for rehearing en bane is DENIED. RICHARD M. RAGSDALE, M.D., et al., Plaintiffs, VS. BERNARD J. TURNOCK, et al., Defendants. No. 85 C 6011 - Judge Nordberg CLASS CERTIFICATION AND PRELIMINARY INJUNCTION ORDER This matter came to be heard upon plaintiffs' motion for class certification and upon plaintiff's motion for a pre- liminary injunction to enjoin and restrain defendants from enforcing § 16.1(a)-(e) of the Illinois Medical Practice Act, III. Rev. Stat. ch. 111, § 4433(a)-(e) ("the MPA"), the Illi- nois Ambulatory Surgical Treatment Center Act, III. Rev. Stat. ch. 111½, 9 157-8.1, et seq. ("the ASTC Act"), regula- tions promulgated under the ASTC Act, and the Illinois Health Facilities Planning Act, Ill. Rev. Stat. ch. 111½, § 1152-1168 ("the HFP Act"), against persons offering, performing, or desiring to offer or perform first or early second trimester abortions. The parties presented evi- dence and argument to the Court in hearings November 18-22 and November 26, 1985, and memoranda of law. Based upon the evidence, arguments and memoranda pre- Judge Kenneth F. Ripple did not participate in the consideration sented to the Court, on November 27, 1985 the Court of the suggestion for rehearing en banc. issued a Memorandum Opinion and Order granting plain- App. 110 App. 111 tiffs' motion for class certification and plaintiffs' motion (c) Enforcing or applying the HFP Act, III. Rev. for preliminary injunction. Stat. ch. 111½, $ 1152-1168, against any person or Based upon this Court's November 27, 1985 Memoran- facility to the extent such person or facility offers dum Opinion and Order and the findings of fact and con- or performs, or desires to offer or perform, first and/ clusions of law therein, IT IS HEREBY ORDERED, AD. or early second trimester abortions or other abortion- JUDGED AND DECREED as follows: related gynecological procedures, such as a dilation and curettage; 1. This matter shall be maintained as a class action. The Court hereby certifies the following classes: (d) Initiating any prosecution against, including but not limited to civil and administrative proceedings, (a) A plaintiff class consisting of all physicians and or imposing any sanction upon any person who offers surgeons who perform or desire to perform abortions or performs or desires to offer or perform first and/ in the State of Illinois; or early second trimester abortions or other abortion- (b) A plaintiff class consisting of all Illinois women related gynecological procedures, such as a dilation of child-bearing age who desire or may desire an and curettage, in violation of § 16.1(a)-(e) of the MPA, abortion sometime in the future; the ASTC Act, or any of its provisions, or rules and (c) A defendant class consisting of all State's Attor- regulations promulgated thereunder, or the HFP Act. neys in the State of Illinois. 3. This order shall be effective immediately and shall 2. Until further order of this Court, defendants Bernard supplement this Court's November 27, 1985 order. J. Turnock, Neil F. Hartigan, and Gary L. Clayton, in 4. The $2,000 bond given by plaintiffs on November 27, their official capacities, and their successors, officers, 1985 and then approved by the Court shall also secure agents, servants, employees, and attorneys, and those per- the preliminary injunction order contained herein. sons in active concert or participation with them, and Richard M. Daley and the other 101 State's Attorneys ENTER: /s/ JOHN A. NORDBERG in Illinois, their successors, officers, agents, servants, em- United States District ployees and attorneys and those persons in active con- Court Judge cert or participation with them, are hereby enjoined from the following actions: Date: December 11, 1985 (a) Enforcing $ 16.1(a)-(e) of the MPA, III. Rev. Stat. ch. 111, § 4433(a)-(e); (b) Enforcing or applying the ASTC Act, III. Rev. Stat. ch. 111½, 157-8.1 et seq., or any of its provi- sions, or rules or regulations promulgated thereunder, against any person or facility to the extent such per- son or facility offers or performs, or desires to offer or perform, first and/or early second trimester abor- tions or other abortion-related gynecological proced- ures, such as a dilation and curettage; App. 112 App. 113 APPENDIX G named plaintiff, Dr. Richard M. Ragsdale; (2) a plaintiff class of "all women in the state of Illinois of child-bear- [Entered November 27, 1985] ing age who desire or may desire an abortion sometime in the future," represented by named plaintiffs Sarah Roe IN THE UNITED STATES DISTRICT COURT and Margaret Moe; and (3) a defendant class of "the State's FOR THE NORTHERN DISTRICT OF ILLINOIS Attorneys for all of the counties of the state of Illinois," EASTERN DIVISION represented by named defendant, Richard M. Daley. The plaintiffs have also moved the court to enjoin defendants from enforcing, in derogation of a physician's right to per- RICHARD M. RAGSDALE, M.D., et al., form, and a woman's right to obtain, first and early sec- Plaintiffs, ond trimester abortions, three Illinois statutes: (1) Sec- V. tion 16(1) of the Illinois Medical Practice Act ("MPA"), III. Rev. Stat. ch. 111, para. 4433(1); (2) the Ambulatory BERNARD J. TURNOCK, et al., Surgical Treatment Center Act of Illinois ("ASTCA"), III. Defendants. Rev. Stat. ch. 111½, para. 157-8.1 157-8.16, and the regu- lations promulgated thereunder; and (3) the Illinois Health No. 85 C 6011 - Judge Nordberg Facilities Planning Act ("HFPA"), III. Rev. Stat. ch. 111½, para. 1151-1168, and the regulations promulgated there- under. MEMORANDUM OPINION AND ORDER The court has reviewed the pleadings of the parties deal- Plaintiffs bring this action against defendants pursuant ing with the class certification motion. The court held a to 42 U.S.C. §§ 1983, 1988 and 28 U.S.C. §§ 2201, 2202, hearing on the motion for preliminary injunction on No- seeking declaratory and injunctive relief. Plaintiffs chal- vember 18-22 and 26, 1985. The court has reviewed the lenge the constitutionality of three Illinois statutes, and pleadings dealing with the preliminary injunction motion, the regulations thereunder, which, plaintiffs contend, form and has heard the opening statements and closing argu- a scheme that in effect requires all abortions to be per- ments of counsel and the testimony of witnesses. The formed in a hospital or its functional equivalent. Plain- court has considered all the evidence presented, including tiffs charge that this scheme violates the equal protec- the depositions of several witnesses who did not testify tion rights of Illinois physicians who perform or desire at the hearing. The court has drawn reasonable inferences to perform abortions, and the privacy rights of Illinois from this evidence, and has evaluated the legal arguments women who desire or may desire to obtain an abortion. presented by the parties. In judging the credibility of each witness and the weight to be given the testimony of each, This matter is now before the court on the motions of the court has taken into account for each witness the in- plaintiffs to certify two plaintiff classes and one defen- telligence, ability and opportunity to observe, the age, the dant class, and for a preliminary injunction against defen- memory, the manner while testifying, any interest, bias, dants. The plaintiffs have moved the court to maintain the or prejudice the witness may have, and the reasonableness following classes: (1) a plaintiff class of "all duly licensed of the testimony considered in the light of all the evidence physicians and surgeons performing or desiring to per- in the case. The court has reviewed its extensive hearing form pregnancy terminations in Illinois," represented by notes and its references concerning credibility. App. 114 App. 115 Based on all of the evidence and legal arguments pre- cerns, for the most part, the requirements and the proced- sented, and for the reasons set forth below, the court ure for obtaining an ASTC license. One other provision of grants, with some modification, plaintiffs' motion for certi- the ASTCA deals specifically with abortion, and that is fication of the three classes, and the court grants plain- section 6.1, which requires any corporation operating an tiffs' motion for a preliminary injunction. A preliminary ASTC devoted primarily to providing facilities for abortion consideration of the challenged statutes and regulations, to have a physician, who is licensed to practice medicine and of the facts, will greatly aid in the discussion of both in all of its branches and is actively engaged in the prac- motions. Therefore, the court now turns to the statutes tice of medicine at the ASTC, on the ASTC's board of and regulations, and to the facts. directors as a condition to licensure of the ASTC. The regulations promulgated pursuant to the ASTCA I. The Challenged Statutes and Regulations are comprehensive and detailed. They cover all aspects The statutes and regulations which plaintiffs challenge of the provision of abortion services, from personnel poli- in this action present an unusual mixture of abortion-spe- cies to physical plant requirements. Many of the regula- cific and general provisions.¹ First, section 16 of the MPA tions are abortion-specific. An entire section of the regula- generally provides the grounds upon which the IDPH may tions, Subpart G, is abortion-specific. The regulations in revoke or suspend the medical license of any person. How- subpart G include a prohibition upon the performance of ever, subsection (1), the only portion of section 16 which abortions after the first trimester and reporting require- plaintiffs challenge, is abortion-specific. Under subsection ments for each abortion performed in an ASTC. (1), the IDPH may revoke or suspend the license of any The physical plant requirements in the regulations cover physician who performs an "elective abortion" in any place building design, construction standards, physical require- other than an ASTC, a hospital, or a facility run by the state, ments and mechanical and electrical systems. In effect, the federal government, or a state university or college. Es- they require ASTCs to be the functional equivalent of sentially, section 16(1) prohibits physicians from performing small hospitals.² These regulations include, but are not even one abortion in their offices, and requires physicians limited to, the following: who wish to provide abortion services in non-hospital en- vironments to comply with the ASTCA and HFPA. (a) Regulation 205.1320(a), requires an ASTC to be "identifiably separate" from other [medical] facil- The ASTCA defines what an ASTC is and provides for ities and functions. the licensure of all ASTCs. Section 3 of the ASTCA defines an ASTC as "any institution, place or building devoted pri- (b) Regulation 205.1330, requires anyone seeking to marily to the maintenance and operation of facilities for build or substantially remodel an ASTC to submit the performance of surgical procedures or any facility in work plans to the state for prior approval. These which a medical or surgical procedure is utilized to termi- work plans include architectural drawings, struc- tural drawings, and mechanical drawings (which in- nate a pregnancy, irrespective of whether the facility is devoted primarily to this purpose." Thus, the ASTCA ap- clude drawings of the heating, cooling, ventilation, plies generally to all ASTCs devoted primarily to the per- plumbing, drainage, stand-pipe and electrical sys- formance of surgical procedures, regardless of the specific tems). procedure performed, while at the same time the ASTCA (c) Regulation 205.1360(a), requires that an examina- singles out, for more strict regulation, facilities at which tion room be at least 80 square feet in size. abortions are performed. The remainder of the ASTCA con- App. 116 App. 117 (d) Regulation 205.1360(b), requires that a procedure As can be seen, these regulations are extremely detailed. room have a minimum clear area of 250 square feet. The regulations, without question, cause abortion pro- (e) Regulation 205.1370(a), requires an ambulatory sur- viders to incure great construction or renovation costs. gical treatment center to have a "control station" The HFPA requires all "health Care facilities," which located to permit "visual surveillance of all traffic includes all ASTCs, to obtain a "permit," or certificate which enters the operating suite". of need, before acquiring major medical equipment or con- (f) Regulation 205.1370(k), requires that "staff and per- structing or modifying a health care facility. HFPA §§ 3, sonnel facilities be provided for male and female 5. The procedure which the HFPA established for acquir- personnel," including a lounge, lockers, separate ing a certificate of need is as follows: (1) the applicant toilets, and space for changing clothes. must submit a comprehensive application to the Illinois Health Facilities Planning Board ("Board"), HFPA § 6; (g) Regulation 205.1370(n), requires a separate janitorial (2) if there is an Areawide Health Planning Organization, closet exclusively for the surgical suite. the Board forwards the application to this organization (h) Section 205.1380, requires an ambulatory surgical for a period of review which may last up to 120 days, treatment center to establish a "diagnostic facility" HFPA § 8; (3) the Areawide Health Planning Organiza- equipped to perform diagnostic tests far more elab- tion, or the IDPH, must provide an opportunity for a pub- orate and complex than those performed during the lic hearing on the application, and may schedule that hear- course of a pregnancy termination. ing up to 90 days after the receipt of a complete applica- (i) Regulation 205.1400 regulates the size of doors and tion, HFPA § 8; and (4) ultimately, the Board will deter- halls to require that some corridors be at least 8 mine whether to grant or deny the application for a cer- feet in width and that doors to procedure rooms tificate of need based on factors such as the applicant's be at least 3 feet 8 inches wide. These dimensions ability to provide a proper standard of health care ser- parallel the requirements for hospital corridors. vice for the community, the economic feasibility of the project, and the project's consistency with the public in- (j) Section 205.1540 regulates the air conditioning, heat- terest and the orderly and economic development of such ing and ventilation systems to require (a) specific facilities, HFPA $ 6.3 filter efficiencies and (b) air flow systems "balanced" to comply with the detailed ventilation and pressure II. The Facts relationships established by the regulation. Different pressure relationships and air change requirements The uncontroverted facts are as follows. Dr. Ragsdale are specified for the following areas: (1) the proced- is a licensed Illinois physician. He is the Director of the ure room, (2) the examination area, (3) the recovery Northern Illinois Women's Center ("NIWC"), which is room, (4) the instrument cleaning room, (5) the toilet located in Rockford, Illinois. The NIWC provides gyneco- room, (6) the janitors' closet, (7) the linen and trash logical, family planning and abortion services to women area, (8) the anesthesia storage area, (9) the equip- in northwest Illinois. ment storage area, (10) the clean linen and storage Since it opened in 1973, the NIWC has been the only area, (11) the soiled linen storage area, (12) the lab- provider of abortion services in the large area of north- oratory area, and (13) miscellaneous other areas. west Illinois. This geographic area extends west to Chi- cago, east to Iowa, north to Wisconsin, and south to App. 118 App. 119 Peoria. The NIWC offers first trimester and early second garet Moe's facilities offer complete family planning edu- trimester "Dilation and Evacuation" abortions, all per- cation and medical care, including the prescription of con- formed with a local anesthetic. The NIWC provides either traceptives, pre-natal care and delivery-assistance for preg- reduced fee or free abortion services to indigent women. nant women. In 1984, physicians at the NIWC performed 3,480 abor- Margaret Moe receives approximately 60 requests for tions. Few complications resulted.4 abortions per week at her clinics. She would like to offer The NIWC is currently licensed under the ASTC, and abortion services at her facilities, and the licensed physi- has been SO since 1973, although at no time has the NIWC cians she employs are competently trained and willing to fully complied with the ASTCA and its regulations.5 The perform safe abortions. However, Margaret Moe's facilities current location of the NIWC is the Rockford Medical do not comply with the physical plant, structural and ad- Arts Building, which is operated by the Rockford Services ministrative requirements of the ASTCA and its regula- Company. tions. As set forth more fully below, Margaret Moe has In early February, 1985, the Rockford Services Com- not, and cannot, renovate her existing facilities or con- pany informed Dr. Ragsdale that his lease would not be struct new facilities that would comply with the ASTCA renewed. The fundamental reason the Rockford Services and its regulations because of the prohibitive cost of such Company did not renew Dr. Ragsdale's lease, as set out a project. in the telephonic deposition of Mr. Delts, the President The two other named plaintiffs are Sarah Roe and Jane of the Rockford Services Company, is that the premises Doe. Sarah Roe is a female citizen of the United States, of the NIWC are needed as office space for physicians of child-bearing age and a resident of Rockford, Illinois. that refer more patients to the adjoining Rockford Me- She is the mother of two children. Ms. Roe had an abor- morial Hospital. Deposition of William Delts, p. 15. Another tion at the Northern Illinois Women's Center for which factor in the decision, however, was the determination she was charged only a minimal fee because of her cur- that it would cost approximately $240,000 for the building rent indigent financial situation. She may need another to be brought into compliance with the ASTCA and its abortion in the future. Jane Doe is a female citizen of the regulations. Id. at 8, 9, 14. United States and of child-bearing age. She is a resident Since the Rockford Services Company informed him that of Rockford, married and the mother of several children. From other doctors in the Rockford area, Ms. Doe learned his lease would not be renewed, Dr. Ragsdale has at- that uterine fibroids associated with a recent pregnancy tempted to find new facilities and secure a certificate of need for such facilities. Dr. Ragsdale, for reasons set forth posed a serious risk to her health; she was told that it below in detail, has not been able to secure a relocation was unlikely she would be able to carry her pregnancy site for the NIWC. On December 31, 1985, the NIWC past five months. Despite the severe pain and emotional trauma associated with this health threat, Ms. Doe was must vacate its premises in the Rockford Medical Arts refused abortion services by several doctors in Rockford. Building. At that time, because of a lack of a relocation site, the NIWC will be forced to close altogether. Finally she was referred to Dr. Ragsdale at the NIWC from whom Ms. Doe received an abortion. Margaret Moe is a registered nurse, and she currently operates two medical facilities, one in Elgin, Illinois, and III. Motion For Class Certification another in Palatine, Illinois. The Elgin facility is in Kane County, and the Palatine facility is in Cook County. Mar- As stated above, plaintiffs have moved the court to maintain the following classes: (1) a plaintiff class of "all App. 120 App. 121 duly licensed physicians and surgeons performing or desir- court now considers whether the proposed classes meet ing to perform pregnancy terminations in Illinois," repre- the class action requirements of Rule 23. sented by named plaintiff, Dr. Ragsdale; (2) a plaintiff class of "all women in the state of Illinois of child-bearing A. The Plaintiff Class of Physicians age who desire or may desire an abortion sometime in the future," represented by named plaintiffs, Margaret This proposed class consists of all duly licensed physi- Moe and Sarah Roe; and (3) a defendant class of "the cians and surgeons performing or desiring to perform State's Attorneys for all of the counties of the State of pregnancy terminations in Illinois, and the proposed rep- Illinois," represented by named defendant, Richard M. resentative of this class is Dr. Ragsdale. The court finds Daley. Defendants Bernard J. Turnock, Director of the that the requirements of Rule 23 are met as to this class Illinois Department of Public Health ("IDPH"), Neil F. and its representative, Dr. Ragsdale. Hartigan, Attorney General of Illinois, and Gary L. Clay- First, this proposed class of plaintiffs is SO numerous ton, Director of the Illinois Department of Registration that it would be impracticable to individually join all of and Education ("IDRE"), through their counsel, have op- its members. Although plaintiffs did not present direct posed the certification of the plaintiff classes. In addition, evidence of the number of class members, plaintiffs did defendant Richard M. Daley, through his attorney, has state that there are approximately 65,860 abortions per- objected to being named as the representative of the de- formed in Illinois annually. Plaintiffs' Motion to Maintain fendant class of Illinois State's Attorneys. Class Actions, p. 3. In addition, during the hearing on Rule 23 of the Federal Rules of Civil Procedure governs the motion for preliminary injunction, plaintiff Margaret the certification of classes in federal courts. In order for Moe stated that the physicians she employs in her two a class to be certified, it must meet the four criteria set Illinois health care clinics desire to perform abortions, and out in 23(a) and must also qualify under any one of the that she knew of physicians in Cook, Kane and DuPage subsections of 23(b). The four criteria of 23(a) are that (1) counties who would also perform abortions, but for the the class is so numerous as to make joinder impracticable; challenged statutes and regulations.⁶ This evidence amounts (2) there are common questions of law or fact; (3) the to more than mere speculation or conclusory allegations claims or defenses of the representative parties are typical as to the numerousity of the class. See Valentino v. How- of the claims or defenses of the class; and (4) the repre- lett, 528 F.2d 975, 978 (7th Cir. 1976). Also, although an sentative parties will fairly and adequately protect the in- exact number of class members has not been determined, terests of the class. Subsection (b) provides that a class due to the difficulty in making such a determination, this action may be maintained if the prosecution of separate does not preclude class certification. Vergara v. Hamp- actions would create certain risks, the party opposing the ton, 581 F.2d 1281, 1284 (7th Cir. 1978), cert. denied, 441 class has acted on grounds generally applicable to the U.S. 905 (1979). The court finds that plaintiffs have pre- class, making injunctive and declaratory relief appropri- sented sufficient evidence of the numerousity of this class ate, or the court finds that the questions of law or fact of physicians. common to the members of the class predominate and that Second, there are questions of law or fact common to a class action is the superior method for adjudication of the members of this proposed class. Not all factual or the controversy. The burden of establishing these class re- legal questions raised in a lawsuit need be common, SO quirements rests on plaintiffs. Eggleston v. Chicago Jour- long as a single issue of law or fact is common to all class neymen Plumbers Local Union No. 130, 657 F.2d 890, members. Thillens, Inc. v. Community Currency Exchange 895 (7th Cir. 1981), cert. denied, 455 U.S. 1017 (1982). The App. 122 App. 123 Assoc. of Illinois, 97 F.R.D. 668, 677 (N.D. III. 1983). Also, B. The Plaintiff Class of Women variance in class members' positions on the common issue This proposed class consists of all women in Illinois of should not be dispositive of the decision to certify the child-bearing age who desire or may desire an abortion class action. Id. Here, all Illinois physicians who perform, sometime in the future, and the proposed representatives or desire to perform, abortions are subject to the chal- are Margaret Moe and Sarah Roe. The court finds that lenged statutes and regulations. The question of law com- the requirements of Rule 23 are met as to this class; how- mon to all physicians in this class is whether the statutes ever, the court appoints, as the named representatives and regulations unconstitutionally impede the equal protec- of this class, Margaret Moe and Dr. Ragsdale. The defen- tion right of physicians in this class to practice their pro- dants contend that Sarah Roe does not have standing to fession. assert her own privacy rights, let alone the privacy rights Third, Dr. Ragsdale's claims are typical of the claims of the proposed class members. Such contention need not of the class. As a licensed Illinois physician who performs detain the court at this time, and the court does not de- abortions in the course of his regular medical practice, cide here whether Sarah Roe does have standing, for it Dr. Ragsdale is subject to the challenged statutes and is clear that Margaret Moe and Dr. Ragsdale have stand- regulations in the same manner as all other Illinois physi- ing to litigate this lawsuit on behalf of themselves as well cians performing, or desiring to perform, abortions.⁷ as on behalf of the proposed class of Illinois women. See, Fourth, Dr. Ragsdale will fairly and adequately protect e.g., Westchester Women's Health Organization v. Whalen, the interests of the class. The test of adequacy of repre- 475 F. Supp. 734, 737 (S.D. N.Y. 1979). The court now sentation is two-pronged: (1) the representative must be turns to the requirements of Rule 23. able to conduct the litigation; and (2) the representative's As stated previously, approximately 65,860 abortions are interests must not be antagonistic to those of the class performed in Illinois annually. Clearly, the proposed class members. Thillens, 97 F.R.D. at 679. Dr. Ragsdale has is so numerous as to make joinder impracticable. Also, clearly demonstrated his ability to conduct the litigation as noted before, the difficulty in determining the exact in the preliminary injunction proceedings. Furthermore, number of class members does not preclude class certifi- his attorneys have considerable experience in civil rights cation. litigation. Also, Dr. Ragsdale does not have interests an- There is a question of law common to all members of tagonistic to the interests of the class. the proposed class. The common question of law is whether Finally, this proposed class meets the requirements of the challenged statutes and regulations unconstitutional- 23(b)(2), as the defendants, in either promulgating, admin- ly burden the right to privacy of the class members. istering or enforcing the challenged statutes and regula- As for the typicality of the claims of Dr. Ragsdale and tions, have acted on grounds generally applicable to the Margaret Moe, and the adequacy of their representation, class, making injunctive and declaratory relief appropriate. the court finds that both of these named plaintiffs clear- Here, plaintiffs seek only injunctive and declaratory re- ly have standing to assert the claims of Illinois women lief.⁸ Finding this class meets the requirements of Rule who desire, or may desire, to obtain an abortion. In 23, the court therefore certifies this plaintiff class and Friendship Medical Center, Ltd. v. Chicago Board of finds Dr. Ragsdale to be an adequate representative. Health, 505 F.2d 1141, 1145-1148 (7th Cir. 1974), cert. denied, 420 U.S. 955 (1975), the Seventh Circuit held that both the physician and the corporate plaintiff had stand- App. 124 App. 125 ing to assert that the abortion regulations unduly infringed Peltason, 359 F. Supp. 320, 323 (N.D. III. 1973) ("As to upon the privacy rights of their patients. In SO holding, the court relied on Doe v. Bolton, 410 U.S. 179 (1973), [the organization's] representation of its members, it would be absurd to hold that an organization has standing in as making it clear that physicians threatened with criminal the constitutional sense, but is barred by the technical re- liability for the performance of an "illegal" abortion do State's abortion law. have a sufficient interest to challenge the validity of a quirements of Rule 23, Fed.R.Civ.P. [citations omitted].") In fact, these representatives seem particularly appropri- ate in light of the fact that persons remain in this class In the present case, Dr. Ragsdale and Margaret Moe for only a short period of time. are not threatened with criminal prosecution, and Mar- As the above discussion establishes, this proposed plain- garet Moe is not a physician. However, as owners and tiff class meets the requirements of section (a) of Rule operators of medical centers, both are threatened, under 23. The proposed class also meets the requirements of the ASTCA and the HFPA, with liability for a "business Rule 23(b)(2), for the same reasons as discussed with offense," punishable by a fine of $10,000.00 for each "vio- regard to the plaintiff class of physicians. The court there- lation." Each day may constitute a separate violation. fore certifies this plaintiff class of Illinois women of child- ASTCA § 12, HFPA § 14. In addition, under the ASTCA, bearing age who desire, or may desire, to obtain an abor- the IDPH may deny, suspend or revoke an ASTC license tion, and finds Margaret Moe and Dr. Ragsdale to be ade- and may even "immediately" close a facility under cer- quate representatives of the class. tain conditions, and, under the HFPA, the Illinois Health Facilities Planning Board may deny an application for a permit needed for the acquisition of major medical equip- C. The Defendant Class of State's Attorneys ment or the construction or modification of a health care This defendant class consists of the State's Attorneys facility. ASTCA §§ 7, 9(a), HFPA § 10.9 Also, Dr. Rags- for all of the 102 counties in the State of Illinois. The dale is threatened, under the MPA, with the revocation named representative is Richard M. Daley, State's Attor- of his medical license. MPA § 16(1). Clearly, both Margaret ney for Cook County, Illinois. Moe and Dr. Ragsdale have an extremely concrete inter- est in the outcome of this litigation, and both therefore Rule 23 unquestionably authorizes the certification of have standing to assert the interests of their patients in defendant classes. Section 23(a) provides, in part: this action. See Birth Control Centers, Inc. v. Reizen, 508 One or more members of a class may sue or be sued F. Supp. 1366, 1369 (E.D. Mich. 1981) (holding that cor- as representative parties on behalf of all only if porate and physician plaintiffs have standing to assert the (3) the claims or defenses of the representative par- claims of their patients), aff'd in part, vac. in part, 743 ties are typical of the claims or defenses of the class F.2d 352 (6th Cir. 1984). [emphasis added]. As the named plaintiffs have standing to assert the Fed.R.Civ.P. 23(2). In addition, Section 23(b) provides that claims of this proposed class of women, the court finds a class action may be maintained if the requisites of Sec- that the requirements of typicality and adequacy of repre- tion 23(a) are met, and "the prosecution of separate ac- sentation have been met. 10 The court finds that the named tions by or against individual members of the class" would plaintiffs are adequate representatives despite the fact create certain risks (emphasis added). See Thillens, 97 that they are not technically members of the proposed F.R.D. at 673. plaintiff class. See Undergraduate Student Association v. App. 126 App. 127 Indeed, in other similar cases in which the plaintiffs Asgrow Seed Co., 425 F.2d 1059 (7th Cir. 1970), the named have questioned the constitutionality of various sections defendant likewise objected to representing the defendant of the Illinois abortion laws, the courts have certified class. In both cases, the courts certified the defendant defendant classes of State's Attorneys, with the State's classes and found the named defendants to be adequate Attorney of Cook County as the named representative. representatives. According to the Research Corp. court, Zbaraz v. Hartigan, 584 F. Supp. 1452, 1454 (N.D. III. the defendants' objection to being the named representa- 1984), modified on other grounds, 763 F.2d 1532 (7th Cir. tives "is hardly enough to overcome the overwhelming evi- 1985) (challenging the Parental Notice Abortion Act and dence of their ability and intention to challenge the plain- designating Richard M. Daley as the representative of tiff's assertions" and "this factor of 'desire,' as opposed all the State's Attorneys of all the counties in Illinois); to ability should not be given more than token weight." Wynn v. Scott, 449 F. Supp. 1302, 1306 (N.D. III. 1978), Research Corp., 301 F. Supp. at 499. See also Thillens, aff'd sub nom., Wynn v. Carey, 599 F.2d 193 (7th Cir. 97 F.R.D. at 679. 1979) (challenging certain sections of the Abortion Act of The Thillens court, however, did discuss the special due 1975); Wynn v. Scott, 448 F. Supp. 997, 1000 (N.D. III. 1978), aff'd sub nom., Wynn v. Carey, 582 F.2d 1375 (7th process concerns which arise upon a motion for certifica- tion of a defendant class. As the court noted, the Su- Cir. 1978) (challenging the Illinois Abortion Parental Con- sent Act of 1977). However, there is no indication that preme Court has balanced the concurrent goals of preserv- the State's Attorney of Cook County, Illinois objected to ing fundamental fairness to absent members of a defen- dant class and promoting judicial economy "by holding representing the class of all Illinois State's Attorneys in these cases. that due process is satisfied and absent members of a class are bound SO long as the interests of the absentees In the present case, Richard M. Daley does object to are adequately represented [citations omitted]." Thillens, being named as the representative of a defendant class 97 F.R.D. at 674. As seen above, the adequacy of the of Illinois State's Attorneys. In his answer to the plain- named representative is not an additional requirement, tiffs' complaint, Mr. Daley "denie(d] that he should be a but a requirement already found in Rule 23. The Thillens class representative" and stated that (1) the class of court, however, demanded that this requirement be "strict- State's Attorneys of all 102 counties in Illinois is not SO ly observed" as to defendant classes, because of the spe- numerous that joinder of all members is impracticable; (2) cial due process concerns. With this in mind, this court it is incorrect to assume that each State's Attorney in now turns to the requirements for class certification found Illinois would assert the same defense to the plaintiff's in Rule 23. claims; and (3) he, through his assistants, generally depends First, the court finds that the class of 102 State's Attor- on the Illinois Attorney General for the defense in cases challenging Illinois abortion laws. Defendant Daley's An- neys, who are dispersed through the State of Illinois, is so numerous that it would be impracticable to individually swer, pp. 2, 3. Mr. Daley, through his attorney, repeated his objection to representative status in a later notice of join its members. Second, the court finds that there are October 30, 1985 and at the hearing on plaintiffs' motion questions of law common to the proposed class of defen- dants. Here, the plaintiffs' claim is that the challenged for preliminary injunction. statutory and regulatory scheme is unconstitutional-that In Thillens, 97 F.R.D. 668, and in Research Corp. v. it violates the privacy rights of women desiring to ob- Pfister Associated Growers, Inc., 301 F. Supp. 497 (N.D. tain abortions and the equal protection rights of physi- III. 1969), appeal dismissed sub nom., Research Corp. v. cians desiring to provide abortion services. The overriding App. 128 App. 129 of the challenged statutes and regulations. common issue of law, therefore, is the constitutionality to obtain an abortion, Section 16(1) of the MPA, the ASTCA and the regulations thereunder, and the HFPA Third, the court finds that the defenses of Richard M. and the regulations thereunder. In ruling on a motion for Daley are typical of the defenses of the class of Illinois a preliminary injunction, the court must consider the fol- State's Attorneys. Obviously, the primary defense of Mr. lowing factors: (1) whether the plaintiffs have no adequate Daley and of all the State's Attorneys in this case will remedy at law and will suffer irreparable harm if the court be that the challenged statutes and regulations are indeed does not grant the preliminary injunction; (2) whether the constitutional. 12 irreparable harm the plaintiffs will suffer outweighs any Finally, the court finds Mr. Daley to be an adequate irreparable harm that may reflect on the defendants if representative of the interests of the class. Mr. Daley, the court issues the injunction; (3) whether the plaintiffs through his staff, has already demonstrated, in the pre- have shown a "better than negligible" likelihood of suc- liminary injunction hearing, his ability to conduct the liti- ceeding on the merits; and (4) whether the injunction will gation. Mr. Daley is sued in his official capacity; therefore, disserve the public interest. Roland Machinery Co. v. no serious question can be raised regarding his ability to Dresser Industries, 749 F.2d 380, 386-387 (7th Cir. 1984). carry the expense of the class defense. Furthermore, Mr. Here, the court finds that all four factors weigh decided- Daley and his staff have considerable litigation experience. ly in favor of issuing a preliminary injunction. Also, Mr. Daley is a member of the proposed class, and his interests in the subject matter of the litigation are A. No Adequate Remedy At Law not antagonistic to the interests of the members of the And Irreparable Harm class of State's Attorneys. Plaintiffs in this case have demonstrated that they will The court therefore finds that this proposed class meets indeed experience irreparable harm should the court not the requirements of section (a) of Rule 23. This class also issue this injunction. The challenged statutory and regu- meets the requirements of section (b)(1) of Rule 23. The latory scheme, as written and as enforced, has the effect prosecution of separate actions against individual members of raising the cost and limiting the availability of abor- of the defendant class would indeed create a risk of in- tions. The scheme forces complying facilities to raise their consistent or varying adjudications, and plaintiffs would fees, possibly beyond the economic means of some women, thereby be faced with incompatible standards of conduct. discourages other non-complying facilities from offering Having found that the requirements of Rule 23 have been abortion services, and makes it difficult, if not impossi- met as to this class, the court now certifies this defen- ble, for current abortion facilities to move or new abor- dant class of Illinois State's Attorneys, represented by tion facilities to be constructed. named defendant Mr. Daley. In Fox Valley Reproductive Health Care v. Arft, 446 F. Supp. 1072, 1073-1074 (E.D. Wisc. 1978), the court found IV. Motion For Preliminary Injunction that the plaintiff abortion clinic sufficiently established ir- As stated above, plaintiffs have moved the court to pre- reparable harm. The town ordinance challenged in that liminarily enjoin defendants from administering and en- case is very similar to the ASTCA and its regulations forcing, in derogation of the equal protection rights of here, in that (1) the town ordinance applied generally to physicians who perform, or desire to perform, abortions any nonhospital facility at which surgical, diagnostic, or and privacy rights of women who desire, or may desire, therapeutic procedures were performed; (2) certain pro- visions applied specifically to abortion clinics; and (3) the App. 130 App. 131 ordinance was comprehensive, regulating licensing, build- out in the HFPA, those desiring to open or move to a ing plans and specifications, supplies and equipment, medi- new facility must complete a lengthy, detailed applica- cal policies and procedures, record keeping, patient care, tion, 15 in which the applicant must disclose the fact that and physician and nurse qualifications. The plaintiff in For abortions will be performed at the proposed facility and Valley contended that irreparable harm was threatened, must identify the ownership of the proposed facility. The because the high cost of bringing the facility in compliance general public may obtain a copy of this application through with the ordinance would force it to raise its current fee the state freedom of information law. 16 Ill. Rev. Stat. ch. of $150 to a fee of between $300 and $500, an amount 116, para. 201, et seq. Also, as part of the certificate of which would be beyond the economic means of poor women. need process, the "recognized areawide health planning The court held that this contention, "in conjunction with organization" or the IDPH must provide an opportunity the solicitude courts have shown for a woman's right to for, and notice of, a public hearing "for the purpose of freedom from interference in deciding whether to seek an allowing the applicant and any interested person to pre- abortion," supported a finding that irreparable harm was sent public testimony concerning the approval, denial, re- threatened. Fox Valley, 446 F. Supp. at 1074. newal or revocation of the [certificate of need]." HFPA In the present case, plaintiffs have also demonstrated § 8. that the extensive regulations force those offering abor- Given the current climate of the abortion debate, placing tion services to raise their fees for abortion services. 13 information in the hands of the public, such as the owner- This may indeed place the abortion procedure beyond the ship of a facility in which persons propose to provide abor- economic means of some women. tion services, subjects both the owner of the building and Plaintiffs have also demonstrated that the extensive the proposed provider to the possibility of harrassment ASTCA regulations discourage or "chill" those desiring and even threats of violence to themselves, their families to offer abortion services from opening an abortion facil- and their friends. 17 In the case of Dr. Ragsdale, after the ity or from adding abortion services to the services they public received notice of a hearing on a proposed new site already provide at their facilities. Margaret Moe testified for the NIWC, but before the hearing took place, the at the hearing that she has desired to offer abortion ser- landlord of the proposed site, with whom Dr. Ragsdale vices at the two health care clinics she operates since had an informal agreement, withdrew the site. Dr. Rags- 1974. She contacted the IDPH on various occasions from dale secured a second site before the public hearing. Dr. 1974-1982, and was told on each occasion that abortion Ragsdale entered a formal agreement with the landlord facilities must secure an ASTC license and comply with of this second site. Approximately 1,200 people attended the ASTCA regulations.¹⁴ Because of the extensive, ex- the hearing on March 14, 1985. The hearing began at 7:00 pensive, and, indeed, prohibitive physical plant require- p.m. with a statement by Dr. Ragsdale announcing the ments in the regulations, Margaret Moe decided she could NIWC's proposed move. No other statement could be not offer abortion services at her clinics, and she still does heard for the rest of the hearing, which lasted until 10:00 not offer abortion services at her clinics. p.m., because of the shouting and generally riotous atmos- phere. Friends of Dr. Ragsdale, fearing for his safety, es- In addition, plaintiffs have also shown that the certifi- corted the Ragsdale family from the hearing. The landlord cate of need requirement of the HFPA makes it extreme- for the second site withdrew the site within 48 hours of ly difficult, if not impossible, for those desiring to pro- the hearing, despite the formal agreement he had entered vide abortion services to construct a facility or move to with Dr. Ragsdale. The areawide health planning organiza- a new location. Under the certificate of need process set App. 132 App. 133 tion in the area of the proposed new sites of the NIWC abortion facility may delay the abortion and thereby in- did eventually determine that there was a need for the crease the health risk or prevent the abortion altogether. NIWC. 18 However, by the time this determination was Also, travelling a distance subjects a woman to greater made, Dr. Ragsdale no longer had a site to which he could expense, as the woman must pay for the cost of transpor- move the NIWC. As it now stands, the NIWC, the only tation and may need to hire a babysitter or miss a day outpatient abortion facility in all of northwest Illinois, will of work and lose that day's pay. In addition, other fac- close December 31, 1985 without a relocation site. tors affecting a woman's decision to terminate her preg- In her testimony at the hearing, Margaret Moe pointed nancy, such as her confidence in the competency of the out yet another way in which the certificate of need pro- physician performing the abortion and her ability to return cedure under the HFPA impedes efforts to provide abor- for follow-up care, would be adversely affected if the tion services. Recently, many hospitals have had difficul- woman were required to travel a great distance to ob- ty filling their available beds because of the emphasis on tain an abortion.20 outpatient health care. With many empty hospital beds, The court finds that plaintiffs have clearly established it may be difficult for those who desire to provide abor- that irreparable injury will result if the injunction is not tion services to establish a "need" for an outpatient abor- issued. See Doe v. Charleston Area Medical Center, 529 tion facility. F.2d 638, 644 (4th Cir. 1975) ("Roe v. Wade and Doe v. Bolton As the above discussion makes clear, the challenged establish beyond argument that denial under statutes and regulations do place a very real and a very color of law of the right to abort, implicit in the right heavy burden on the right of a woman to decide to ter- to be let alone, constitutes irreparable injury.") Accord, minate her pregnancy. The effect of the statutory and Gary-Northwest Indiana Women's Services, Inc. v. Bowen, regulatory scheme is to increase the cost of abortions and 496 F. Supp. 894, 902 (N.D. Ind. 1980). decrease their availability. As a result of the scheme, The court finds that plaintiffs have established irrepar- Margaret Moe does not provide abortion services at her able injury despite the argument of defendants that ir- two Illinois clinics even though the physicians at the reparable injury is not established because the IDPH does clinics are ready, willing, and able to perform abortions, not enforce certain sections of the statutes and certain and even though approximately sixty patients a week at regulations. The State asserted in the hearing that the the clinics request an abortion. Also, as a result of the IDPH does not currently enforce the following statutes scheme, the NIWC, the only outpatient abortion facility and regulations: (1) MPA § 16(1), requiring abortions to in northwest Illinois, will close at the end of this year be performed in an ASTC or hospital; (2) ASTCA $ 3(A), without a relocation site. defining an ASTC as including any facility in which a The effect on women desiring to terminate their preg- medical procedure is utilized to terminate a pregnancy, nancies, as clarified by the hearing testimony of Margaret regardless of whether the facility is primarily devoted to Moe, is enormous. First, many women are not able to ob- this purpose; (3) Regulation 205.740, prohibiting the per- tain an abortion in their own community, and they may formance of other than first trimester abortions in ASTCs; find it difficult to secure a means of transportation to the and (4) Regulation 205.760, requiring a report of each nearest abortion facility, which may, in fact, be quite a abortion procedure performed in an ASTC. distance from their community. Having to make travel However, the IDPH has on no occasion formally notified plans, arrange a day off and negotiate a loan, if needed, physicians or abortion providers of its decision not to en- and then actually having to travel some distance to an force these provisions. Also, the IDPH has not attempted App. 134 App. 135 to amend the regulations or introduce amendatory legisla- to decide whether to obtain an abortion. Id. at 153. At tion in the Illinois legislature. With no formal commitment the same time, the Court acknowledged that this funda- of nonenforcement, the statutory and regulatory require- mental right "is not unqualified and must be considered ments, even if not in fact enforced, clearly "chill" poten- against important state interests in abortion." Id. at 154. tial abortion providers. Moreover, even if there were a However, as pointed out in Roe, 410 U.S. at 155, and formal nonenforcement agreement, the discussion above more recently in City of Akron v. Akron Center for Re- demonstrates that plaintiffs have established irreparable productive Health, 462 U.S. 416, 427 (1983), restrictive injury resulting from the statutory and regulatory scheme, state regulation of the right to choose abortion, as with as written and as enforced. other fundamental rights, must be supported by a compel- The court notes, at this time, the irony implicit in the ling state interest. defendants' nonenforcement argument. At the preliminary In Roe, the Court identified the relevant state interests injunction hearing, Dr. Hern, an expert on abortion prac- and the point at which those interests become compelling. tice, testified that most important factor in determining According to the Court, the state has an interest in the the safety of an abortion is the skill and experience of health of the mother, and this interest becomes compelling the physician. According to Dr. Hern, a physician who at approximately the end of the first trimester. After the performs only a few abortions a year will be less skilled first trimester, the state may, in promoting this interest, than physicians with a practice "primarily devoted" to the "regulate the abortion procedure in ways that are reason- performance of abortions. Under the statutory and regula- ably related to maternal health." Roe, 410 U.S. at 164. tory scheme, as defendants contend it is now enforced, Until that time, a pregnant woman must be allowed, in physicians performing thousands of abortions yearly are consultation with her physician, to decide to abort and more strictly regulated than physicians performing a few to effectuate that decision "free of interference by the abortions a year. State." Id. at 163; Akron, 462 U.S. at 429-430. The Court in Roe based its identification of the end of B. Harm To The Plaintiffs Outweighs the first trimester as the "compelling point" on the find- Any Harm To Defendants ing that, according to medical literature available in 1973, first trimester abortions are as safe for a woman as nor- The threatened harm to the plaintiffs clearly outweighs any possible harm defendants may suffer if the court mal childbirth. Roe, 410 U.S. at 163. In Akron, the Court issues the preliminary injunction. Indeed, it is difficult to noted that medical developments in the past decade "have discern exactly what, if any, harm will befall defendants extended the period in which abortions are safer than upon the issuance of this injunction, which will merely pre- childbirth." Akron, 462 U.S. at 429, n. 11.2¹ Still, the Akron Court held it "prudent to retain Roe's iden- vent defendants from enforcing the challenged statutes and regulations. See e.g., Fox Valley, 446 F. Supp. at 1074. tification of the beginning of the second trimester as the approximate time at which the State's interest in mater- nal health becomes sufficiently compelling (emphasis C. Likelihood of Success On The Merits added)." Id. The court now turns to the Roe trimester In the landmark case of Roe v. Wade, 410 U.S. 113 standard, as interpreted in Akron and other cases, to pro- (1973), the Supreme Court established that the right of vide the legal framework for the constitutional evaluation privacy, grounded in the concept of personal liberty guar- of the challenged statutes and regulations. anteed by the Constitution, encompasses a woman's right App. 136 App. 137 First, the court notes that the statutes and regulations Thus, any regulation, even a general regulation, which here apply to all facilities in which any abortions are per- burdens a woman's rights to choose to terminate her preg- formed. None of the statutes or regulations exclude from nancy during the first trimester would have to meet the their scope facilities in which first or early second tri- compelling governmental interest requirement. In addi- mester abortions are performed. However, this does not tion, under Roe and Akron, a regulation which burdens mean that the statutes and regulations are per se uncon- a woman's right to choose to terminate her pregnancy stitutional. As the Akron court noted, certain State regu- during the early second trimester must be "reasonably lations that have no "significant impact" on a woman's relate[d]" to the preservation and protection of maternal exercise of her abortion right during the first trimester health. Akron, 462 U.S. at 430-431; Roe, 410 U.S. at 163. may be permissible where justified by important State In the present case, plaintiffs have overwhelmingly dem- health objectives. Akron, 462 U.S. at 430. See Planned onstrated the burden that the challenged statutory and Parenthood of Central Missouri v. Danforth, 428 U.S. 52 regulatory scheme places on a woman's right to choose (1976) (upholding regulations which applied to first tri- to terminate her pregnancy during the first and early sec- mester abortions and required that a patient give writ- ond trimester. As noted in the previous discussion of ir- ten consent prior to the abortion, and that records be kept reparable injury, the scheme, as written and as enforced, of all abortions); Connecticut v. Menillo, 423 U.S. 9 (1975) increases the cost and decreases the availability of abor- (upholding a statute requiring that only licensed physicians tions. Also, the scheme may delay the effectuation of a perform abortions, including first trimester abortions). woman's decision to abort. Neither does Roe stand for the proposition that any gen- Charles v. Carey, 627 F.2d 772, 777 (7th Cir. 1980), app. eral medical regulation which applies to the performance after remand, sub nom. Charles v. Daley, 749 F.2d 452 of first and early second trimester abortions is per se con- (7th Cir. 1984), instructs that once a plaintiff has shown stitutional. As the Seventh Circuit stated in Friendship that interference in the pregnancy termination decision Medical Center, Ltd. v. Chicago Board of Health, 505 F.2d is "sufficiently substantial and not de minimus," the State 1141, 1153-1154 (7th Cir. 1974), cert. denied, 420 U.S. 955 must show that there is compelling basis for the law and (1975): that the burden is not undue or unjustifiable. Here, plain- Furthermore, any proposed regulation, even if applied tiffs have demonstrated that the challenged scheme sub- universally to all similar medical procedures, because stantially interferes with the pregnancy termination deci- of the fundamental right of a woman to procure an sion during the first and early second trimester. abortion during the first trimester, would have to Defendants, however, have failed to produce any evi- meet a compelling governmental interest requirement. dence at all of a compelling or even rational basis for the Thus, any general health regulations which would ap- challenged statutes and regulations. The defendants pre- ply to first trimester abortions would have to be sented no evidence in their pleadings or at the hearing limited so as to give effect to the fundamental rights that the statutes and regulations are medically necessary. 23 as established by Roe and Doe; that is, not be bur- Dr. Barton, the defendant's expert in obstetries and gyne- densome on a woman's right to decide to abort a cology, testified at the hearing that he was of the opinion pregnancy. By this we mean that in all probability that there is a medical necessity for some regulation by nothing broader than general requirements as to the the state of outpatient abortion facilities, but Dr. Barton maintaining of sanitary facilities and general re- did not testify as to the medical necessity of any of the quirements as to meeting minimal building code statutes or regulations here challenged. Also, Dr. Barton standards would be permissible. (Emphasis added.) App. 138 App. 139 agreed that there is no medical reason to single out abor- by local building codes. Also, physicians performing abor- tion from other medically analogous procedures for differ- tions are obligated to practice surgery with care and will ent regulation. Defendants, at best, have shown that still be subject to disciplinary action under the remaining selected regulations, such as Regulation 205.730(b)(2)(a), subsections of section 16 of the MPA. The court therefore which sets out the qualifications for counselors, are con- finds that the public interest will be served by the issu- sistent with accepted medical practice. This is not equiva- ance of this preliminary injunction. lent to a showing of medical necessity. Plaintiffs have established the burdensome nature of the E. Scope of The Preliminary Injunction scheme as a whole. Defendants have failed to demonstrate Having found preliminary injunctive relief is appropriate a compelling, or even a rational, basis for the statutory in this case, the court now turns to the scope of the pre- and regulatory scheme. Therefore, the court now finds liminary injunctive relief granted. In the above discussion that there is a reasonable likelihood that plaintiffs will dealing with the plaintiffs' demonstration of the likelihood succeed on the merits. of their success on the merits, the court found that defen- dants have failed to show a compelling need or even a D. Harm To The Public Interest rational basis for the burdensome statutory and regulatory scheme. Accordingly, the court preliminarily enjoins defen- In Fox Valley, 446 F. Supp. at 1075, the court found dants from enforcing the challenged statutes and regula- that the public's interest would not be disserved by the tions against any plaintiffs who offer or perform first or issuance of the preliminary injunction. The court reasoned early second trimester abortions. that the public's interest lies in the enforcement of that which is mandated by the Constitution, and the Constitu- tion mandated that the abortion regulation challenged in V. Conclusion that case not be imposed. Likewise, in the present case, For the reasons set forth above, the court grants plain- the Constitution mandates that the challenged statute and tiffs' motion for certification of two plaintiff classes and regulations not be applied to physicians who perform first one defendant class, with some modification. Also, the trimester abortions or early second trimester DE abor- court grants plaintiffs' motion for preliminary injunction, tions, or to the facilities in which these procedures are and hereby enjoins defendants from enforcing the chal- performed. lenged statutes and regulations against any plaintiff offer- Of course, the public also has an interest in the preser- ing, performing, or desiring to offer or perform a first vation and protection of a patient's health. However, con- or early second trimester abortion. trary to the argument of the State's Attorney at the pre- liminary injunction hearing, the injunction which the court ENTER: /s/ JOHN A. NORDBERG now issues will not disserve this interest. At the hear- United States District Judge ing, the State's Attorney argued that, if the court issued the injunction prayed for, this would "open the door" to substandard abortion facilities in Illinois. Not so. The in- Date: November 27, 1985 junction here will not leave abortion clinics, such as the NIWC, free from all state regulation. On the contrary, such facilities will still have to meet the standards set App. 140 App. 141 I The challenged statutes are not part of the explicitly separate in a few days after an abortion at the NIWC, such as a fever Illinois "Abortion Laws," III. Rev. Stat. ch. 38, para. 81-21 to 81. from infection. These extremely low complication rates attest to 35, 81-51 to 81-55, 81-61 to 81-70, the constitutionality of which has Dr. Ragsdale's skill and experience as an abortion provider. Both been challenged on several occasions. See, e.g., Zbaruz ". Hartigan, Margaret Moe, an expert in the area of women's health care and 763 F.2d 1532 (7th Cir. 1985); Charles " Carey, 627 F.2d 772 (7th family planning, and Dr. Hern, an expert on abortion practice, tes- Cir. 1980), appeal after remand sub nom. Charles 11. Daley, 749 tified at the hearing that, in their opinion, Dr. Ragsdale is an ex- F.2d 452 (7th Cir. 1984), probable jurisdiction noted sub nom. Dia- tremely skilled and careful abortion provider. Indeed, even Dr. mond v. Charles, 105 S.Ct. 2356 (1985); Wynn v. Carey, 599 F.2d Barton, the defendants' expert on obstetries and gynecology, testi- 193 (7th Cir. 1979); Wynn v. Carey, 582 F.2d 1375 (7th Cir. 1978). fied that he has "some certainty" that the hospital in which he Likewise, there have been previous challenges to the constitu- works, Illinois Masonic Medical Center, has referred patients to tionality of the statutes involved in this case. In Village of Oak Dr. Ragsdale for abortions. Lawn v. Marcowitz, 86 III. 2d 406, 427 N.E.2d 36 (1981), the Illi- 5 There are currently 44 ASTCs in Illinois. Approximately half nois Supreme Court struck down a portion of a village ordinance, of these provide abortion services. on equal protection and privacy grounds, which incorporated the ASTCA's definition of an Ambulatory Surgical Treatment Center 6 In the preliminary injunction hearing, defendant Richard M. ("ASTC"). Also in Bickham v. Lashof, No. 76 C 4564, slip op. Daley, through his attorney, did point out on cross examination (N.D. III. Jan. 28, 1981), the court denied defendants' motion to of Margaret Moe that Margaret Moe had personally worked with dismiss the allegations in plaintiff's complaint that the ASTCA and physicians in only Cook and Kane Counties. MPA are unconstitutional. However, this case, which dealt with 7 Defendants contend in their Response to the Motion for Class some of the exact issues presented here, was apparently dismissed Certification that Dr. Ragsdale's claims are not typical of those for want of prosecution without a decision on the merits. of the proposed class because the NIWC has been a licensed ASTC 2 Mr. Triemari, a Consulting Engineer and an expert in plumb- since 1973; therefore, "Dr. Ragsdale is challenging the constitution- ing, heating and air conditioning, testified at the injunction hear- ality of the statutes and regulations through which he has bene- fitted for more than ten years." Defendants' Response, p. 3. The ing that the ASTC physical plant regulations are comparable, or court finds this argument without merit. Defendants do not articu- generally equivalent, to those in the Illinois Hospital Licensing late what "benefit" Dr. Ragsdale receives under the challenged Act, Ill.Rev.Stat. ch. 111½, para. 142, et seq., and the Chicago Hos- pital Ordinance. He also testified that many of the requirements, statutes and regulations. Neither do defendants recognize that other members of the proposed class may also have operated licensed such as those dealing with air flow, are not required of physicians' offices. ASTCs for a number of years. It is axiomatic that those to whom statutes and regulations apply may challenge the constitutional- 3 Raymond Passeri, the Chief of the Division of Facilities De- ity of such statutes and regulations despite a period of compliance. velopment at the IDPH and the Executive Secretary of the Board, See, e.g., Friendship Medical Center, Ltd. v. Chicago Board of Health, testified at the hearing that the HFPA was enacted in part be- 505 F.2d 1141, 1146 (7th Cir. 1974), cert. denied, 420 U.S. 955 cause of the concern that allowing an unlimited number of health (1975). Indeed, under the standing requirements of Article III of care facilities to be constructed would not fill a "need," but would the United States Constitution, as interpreted by the courts, par- instead waste the Illinois taxpayers' money because of the cost- ties against whom statutes and regulations directly operate may plus disbursement arrangement. This arrangement is no longer in be the "best" plaintiffs for a constitutional challenge, given their effect, and, certainly, abortion facilities do not utilize public funds concrete personal stake in the outcome of the litigation. for construction or renovation; therefore, the certificate of need 8 Defendants contend that the declaratory and injunctive relief procedure seems particularly inappropriate as applied to abortion facilities. plaintiffs request can be granted to all class members without cer- tifying a class; therefore, plaintiffs' motion should be denied. In Dr. Ragsdale presented the NIWC's complication statistics at the Seventh Circuit, however, if a class meets the prerequisites the hearing. According to Dr. Ragsdale, approximately 9 women of Rule 23, a court may not deny class certification on the ground per 40,000 require immediate hospitalization after having an abor- of lack of "need." Brown v. Scott, 602 F.2d 791, 795 (7th Cir. 1979), tion at the NIWC, no deaths have resulted from abortions at the aff'd sub nom. Carey v. Brown, 447 U.S. 455 (1980); Vergara, 581 NIWC, and 10 to 15 women per 40,000 develop complications with- F.2d at 1284. App. 142 App. 143 9 In Friendship, the challenged regulations empowered the city action specifically against them. This "affirmative defense" in Mr. to deny authorization to those seeking to operate abortion facilities Daley's answer apparently rested on the fact that Dr. Ragsdale's and to order the closing of a facility not in compliance with its clinic was not in Cook County; therefore, Mr. Daley could not pros- regulations. According to the Seventh Circuit, "Surely, those sub- ecute under the ASTCA or HFPA, and Dr. Ragsdale did not ject to such deprivations through the use of governmental power "state a cause of action" against Mr. Daley. Dr. Ragsdale is not have a sufficient interest to maintain this type of action. [citations the only plaintiff, however. Margaret Moe, another named plain- omitted]" Friendship, 505 F.2d at 1146. tiff, owns and operates a medical facility in Cook County, and she 10 Based on the preliminary injunction proceedings, it is clear clearly has stated a cause of action against Mr. Daley. that Dr. Ragsdale and Margaret Moe will adequately represent Given the certification of the two plaintiff classes in this order, the interests of this proposed plaintiff class. In both the pleadings it is expected that few, if any, State's Attorneys will be able to and the hearing on the preliminary injunction motion, the named raise this defense. Accordingly, the court finds that the possibili- plaintiffs, through their attorneys, focused almost exclusively on ty that any one State's Attorney will raise this defense does not the alleged unconstitutional burden that these statutes and regula- substantially affect the "typical" nature of the named defendants' tions place on the right of Illinois women to decide whether to defenses. See Research Corp., 301 F. Supp. at 499. obtain an abortion. 13 Dr. Ragsdale testified at the preliminary injunction hearing 11 The Thillens court also discussed the problems inherent in that his current fee for an abortion is approximately $250. Dr. certifying both plaintiff and defendant classes in the same action. Ragsdale estimated that if he were to move his practice to a facil- Thillens, 97 F.R.D. at 675-76. The court noted that courts are ity similar to his current facility, which does not fully comply with often reluctant to certify a defendant class when the action is the ASTCA regulations, he would have to increase by $22.45 the brought by a plaintiff class because of the concern that each plain- fee per patient over the next two years to cover his costs. Plain- tiff member has not been injured by each defendant member. How- tiffs' Exhibit No. 17. Relocating his practice to a building in total ever, according to the court, as it interpreted In re Gap Stores compliance with the regulations, on the other hand, would add Securities Litigation, 79 F.R.D. 283 (N.D. Cal. 1978), the require- another $25.21 to the increase, making the total increase in fee ment that each named plaintiff have a claim against each defen- per patient $47.66. Plaintiffs' Exhibit No. 18. dant may be waived where the defendant members are related 14 Margaret Moe also testified that she telephoned the IDPH by a conspiracy or "juridical link." The Thillens court went on on November 18, 1985, to find out whether the IDPH still requires to define a "juridical link" as "some legal relationship which all abortion facilities to be licensed. At that time, an employee relates all defendants in a way such that single resolution of the in the division of the ASTC licensing informed her that the IDPH dispute is preferred to a multiplicity of similar actions. [citations was not currently requiring licenses for abortion facilities, but the omitted]" IDPH "recommended" licensure. Margaret Moe had never before There is clearly a "juridical link" between the Illinois State's been informed that the IDPH was no longer requiring abortion Attorneys here. Under Ill. Rev. Stat. ch. 14, para. 5, each and facilities to obtain ASTC licenses. The court notes that it was not every State's Attorney is charged with the duty of prosecuting clear from this testimony whether the IDPH no longer requires all civil and criminal actions in which the people of the state or ASTC licenses even for facilities "primarily devoted" to the per- county may be concerned. Also, under section 14 of the HFPA, formance of abortions. The testimony of Mary Lloyd Lowe, Deputy which deals with violations, the State's Attorneys are specifically Chief Counsel for the Illinois Department of Public Health, and charged with the duty of representing the people of Illinois in pro- Defendants' Exhibit No. 2, an IDPH internal memorandum written ceedings under that section. As all State's Attorneys are charged by Michael Anderson, indicate that the IDPH still requires licen- under the same statutes with the duty to take uniform enforce- sure for those facilities "primarily devoted" to providing abortion ment action with respect to plaintiffs, the court therefore finds services. that the State's Attorneys are related in a way such that single 15 Dr. Ragsdale testified at the hearing that it took him five resolution of the dispute is preferred to a multiplicity of similar full working days to complete the HFPA application for a certifi- actions. cate of need. 12 Some of the State's Attorneys may contend, as Mr. Daley 16 At the preliminary injunction hearing, Mary Lloyd Lowe tes- did in his Answer, that the plaintiffs have not stated a cause of tified that the IDPH also releases ASTC license applications, when App. 144 App. 145 requested, pursuant to the Illinois Freedom of Information Act. still more sections of the "general" Michigan Public Health Code, Under the ASTCA and its regulations, such applications must also which required all freestanding surgical outpatient facilities to have include a statement of ownership and a description of the services transfer agreements with hospitals and to have six-foot corridors. to be provided. ASTCA § 7(a), 77 III. Admin. Code § 205.120. The 23 Plaintiffs, on the other hand, presented testimony by Dr. ASTC license application is also lengthy and detailed, as demon- Ragsdale and Dr. Hern that the regulations are not only medical- strated by Plaintiffs' Exhibit No. 21, Dr. Ragsdale's 1985 ASTC ly unnecessary, but some of the regulations, particularly those re- license application. quiring ASTCs to be hospital-like facilities, may be medically detri- 17 Dr. Ragsdale testified that the ASTCA requirements that mental, for women often find it psychologically reassuring when an abortion facility be separately licensed and maintain an "identifi- they are able to effectuate their decision to abort in a comfortable, ably separate" facility also subject abortion providers and their more personalized atmosphere. patients to threats and harrassment. Defendants' difficulty in providing evidence of the medical neces- 18 See Plaintiffs' Exhibit No. 11, "Certificate of Need Investiga- sity of the burdensome statutes and regulations challenged here tive Staff Report to the Comprehensive Health Planning of North- is understandable, given that other courts have already found that ern Illinois Regional Board and Project Review Committee." similar or identical provisions burden a woman's right to choose to terminate her pregnancy without furthering a compelling state 19 Margaret Moe testified at the hearing that approximately interest. See Arnold v. Sendak, 416 F. Supp. 22 (S.D. Ind. 1976) 90% of the patients at her Elgin, Illinois clinic have no means of (finding unconstitutional an Indiana statute requiring all abortions transportation, and approximately 50% of the patients at her Pala- to be performed in hospitals or licensed health care facilities), aff'd tine, Illinois clinic have no means of transportation. mem., 429 U.S. 968 (1976); Village of Oak Laum v. Marcowitz, 20 According to Margaret Moe, one of the greatest concerns of 86 III. 2d 406, 427 N.E.2d 36 (1981) (finding the portion of the the patients at her clinics who desire to have an abortion is that definition of an ASTC including "any facility in which a medical Margaret Moe be able to refer them to a physician she knows is or surgical procedure is utilized to terminate a pregnancy, irrespec- competent. Were Margaret Moe able to offer abortion services at tive of whether the facility is devoted primarily to this purpose" her own clinics, she could, of course, assure her patients of the to be unconstitutional). competency of the performing physicians. 21 Dr. Ragsdale and Dr. Hern both testified at the hearing of the safety of the Dilation and Evacuation procedure, which has recently become the method most often utilized for abortions in the early part of the second trimester. In addition, defendants ten- dered as their Exhibit No. 6 the Standards for Obstetric-Gynecolo- gical Services, developed by the American College of Obstetricians and Gynecologists ("ACOG Standards") (6th ed. 1985). According to the ACOG Standards, and as noted by the Akron Court, uncom- plicated abortions, up to 14 weeks from the last menstrual period, may be performed in a physician's office or an outpatient clinic. ACOG Standards, p. 60. 22 In Abortion Coalition v. Michigan Department of Public Health, 426 F. Supp. 471, 474-476 (E.D. Mich. 1977), the court, in dicta, indicated that general regulations imposed upon medical- ly analogous procedures are not invalid as applied to first trimester abortions. However, at the same time, the court held certain pro- visions of the "general" statute to be unconstitutional as applied to first trimester abortions. Moreover, in Birth Control Centers, Inc. v. Reizen, 508 F. Supp. 1366 (E.D. Mich. 1981), aff'd in part, vac. in part, 743 F.2d 352 (6th Cir. 1984), the court struck down App. 146 App. 147 APPENDIX H Professional Regulation,* hereby appeal to the Supreme Court of the United States from judgment of the United NOTICE OF APPEAL States Court of Appeals for the Seventh Circuit affirm- ing an order of the United States District Court, North- [Filed November 7, 1988] ern District of Illinois, Eastern Division, and holding un- IN THE constitutional and enjoining enforcement of the Ambulatory UNITED STATES COURT OF APPEALS Surgical Treatment Center Act and the rules and regula- FOR THE SEVENTH CIRCUIT tions promulgated thereunder; the Health Facilities Plan- ning Act; and par. 4433(1)(a)-(e) of the Illinois Medical No. 85-3242 Practice Act to the extent any person or facility offers or performs, or desires to offer or perform first and/or early second trimester abortions or other abortion-related gynecological procedures. The judgment was entered on RICHARD M. RAGSDALE, M.D., et al., March 10, 1988. On August 12, 1988 the appellants' peti- Plaintiffs-Appellees, tion for rehearing and suggestion for rehearing en bane was denied. VS. This appeal is taken pursuant to 28 U.S.C. Section BERNARD J. TURNOCK, M.D., M.P.H., Director of the Illi- 1254(a). nois Department of Public Health, et al., Defendants-Appellants. Respectfully submitted, NEIL F. HARTIGAN Appeal from the United States District Court Attorney General of Illinois for the Northern District of Illinois, Eastern Division No. 85 C 6011-John Nordberg, Judge Presiding BY: /s/ KATHLEEN KREISEL FLAHAVEN Assistant Attorney General General Law Division NOTICE OF APPEAL TO THE 100 West Randolph Street SUPREME COURT OF THE UNITED STATES 13th Floor Chicago, Illinois 60601 Notice is hereby given that defendants-appellants Bernard J. Turnock, Director of the Illinois Department of Public Health; Neil F. Hartigan, Attorney General of Illinois; and Stephen F. Selcke, Director of the Illinois Department of * Successor in public office to Gary L. Clayton, Director of the Illinois Department of Registration and Education. App. 148 App. 149 AFFIDAVIT OF SERVICE APPENDIX I I hereby aver that a true and correct copy of the fore- going was served upon all parties required to be served at the listed addresses by depositing same in the United Ambulatory Surgical Treatment Center Act, States mail chute located at 100 West Randolph Street, Chicago, Illinois 60601 on the 7th day of November, 1988 111½ III. Rev. Stat. 11 157-8.1, et seq. with proper postage prepaid. AMBULATORY SURGICAL TREATMENT CENTER ACT Alan S. Gilbert Colleen K. Connell AN ACT relating to the inspection, licensing and regula- Lorie A. Chaiten The Roger Baldwin tion of ambulatory surgical treatment centers. P.A. Sonnenschein, Carlin, Foundation of ACLU 78-227, approved and eff. July 19, 1973. Nath & Rosenthal 20 East Jackson Boulevard 8000 Sears Tower Suite 1600 157-8.1. Short title Chicago, Illinois 60606 Chicago, Illinois 60604 § 1. This act may be cited as the Ambulatory Surgical Randolph T. Kemmer Treatment Center Act. Assistant State's Attorney 500 Richard J. Daley Center 157-8.2. Declaration of public policy-Purpose Chicago, Illinois 60602 § 2. It is declared to be the public policy that the State has a legitimate interest in assuring that all medical pro- /s/ KATHLEEN KREISEL FLAHAVEN cedures, including abortions, are performed under circum- stances that insure maximum safety. Therefore, the pur- SUBSCRIBED AND SWORN TO pose of this Act is to provide for the better protection BEFORE ME THIS 7th DAY of the public health through the development, establish- OF NOVEMBER, 1988. ment, and enforcement of standards (1) for the care of individuals in ambulatory surgical treatment centers, and (2) for the construction, maintenance and operation of am- /s/ JANET M. VOLDRICH bulatory surgical treatment centers, which, in light of ad- Notary Public vancing knowledge, will promote safe and adequate treat- ment of such individuals in ambulatory surgical treatment centers. 157-8.3. Definitions § 3. As used in this Act, unless the context otherwise requires, the following words and phrases shall have the meanings ascribed to them: (A) "Ambulatory surgical treatment center" means any institution, place or building devoted primarily to the main- tenance and operation of facilities for the performance of surgical procedures or any facility in which a medical or App. 150 App. 151 surgical procedure is utilized to terminate a pregnancy, (F) "Dentist" means a person licensed to practice den- irrespective of whether the facility is devoted primarily tistry under the "Illinois Dental Practice Act."3 to this purpose. Such facility shall not provide beds or (G) "Podiatrist" means a person licensed to practice other accommodations for the overnight stay of patients. podiatry under "An Act to regulate the practice of podia- Individual patients shall be discharged in an ambulatory try in the State of Illinois", approved April 26, 1917, as condition without danger to the continued well being of amended.4 the patients or shall be transferred to a hospital. Amended by P.A. 83-333, $ 60, eff. Sept. 14, 1983. The term "ambulatory surgical treatment center" does not include (1) any institution, place, building or agency 1 Paragraph 142 et seq. of this chapter. required to be licensed pursuant to the "Hospital Licens- 2 Paragraph 4151-101 et seq. of this chapter. ing Act", approved July 1, 1953, as amended.¹ 3 Chapter 111, 9 2201 et seq. (2) any person or institution required to be licensed 4 Chapter 111, 1 4901 et seq. pursuant to the "Nursing Home Care Reform Act of 1979" approved August 23, 1979, as amended;2 157-8.4. Necessity of license-Municipal regulation (3) hospitals or ambulatory surgical treatment centers $ 4. No person shall open, conduct or maintain an am- maintained by the State of any department or agency bulatory surgical treatment center without first obtain- thereof, where such department or agency has authority ing a license from the Department. under law to establish and enforce standards for the Nothing in this Act shall be construed to impair or hospitals or ambulatory surgical treatment centers under abridge the power of municipalities to license and regulate its management and control; ambulatory surgical treatment centers, provided that the (4) hospitals or ambulatory surgical treatment centers municipal ordinance requires compliance with at least the maintained by the Federal Government or agencies there- minimum requirements developed by the Department pur- of; or suant to this Act. (5) any place, agency, clinic, or practice, public or pri- The Administrative Review Law, as heretofore or here- vate, whether organized for profit or not, devoted exclu- after amended,¹ shall be applicable to the judicial review sively to the performance of dental or oral surgical proce- of final administrative decisions of the regulatory agency dures. of the municipality. Any municipality having an ordinance licensing and regulating ambulatory surgical treatment (B) "Person" means any individual, firm, partnership, centers which provides for minimum standards and regula- corporation, company, association, or joint stock associa- tions which meet at least the minimum requirements es- tion, or the legal successor thereof. tablished pursuant to this Act shall make such periodic (C) "Department" means the Department of Public reports to the Department as the Department may deem Health of the State of Illinois. necessary. This report shall include a list of ambulatory (D) "Director" means the Director of the Department surgical treatment centers meeting standards substantially of Public Health of the State of Illinois. equivalent to those promulgated by the Department under this Act. The Department may issue a license to such am- (E) "Physician" means a person licenced to practice bulatory surgical treatment centers based upon such re- medicine in all of its branches in the State of Illinois. ports or the Department may conduct investigations or App. 152 App. 153 sued inspections to determine whether a license should be is- to these ambulatory surgical treatment centers. (2) The licensure status or record of the applicant, or Amended 1982. by P.A. 82-783, Art. XI, $ 201, eff. July 13, if the applicant is a firm, partnership or association, of any of its members, or if a corporation, of any of its offi- 1 Chapter 110, 1 3-101 et seq. cers or directors, or of the person designated to manage or supervise the facility, from any other state where the applicant has done business in a similar capacity indicates 157-8.5. Application for license that granting a license to the applicant would be detrimen- § 5. An application for a license to operate an ambula- tal to the interests of the public; or tory surgical treatment center shall be made to the De- (3) The applicant has insufficient financial or other re- partment upon forms provided by it and shall contain sources to operate and conduct the facility in accordance information as the Department reasonably requires, which such with the requirements of this Act and the minimum stan- the may include affirmative evidence of ability to comply with dards, rules and regulations promulgated thereunder. regulations, promulgated by virtue thereof. provisions of this Act and the standards, rules and The Director shall only issue a license if he finds that the applicant facility complies with this Act and the rules, All applications required under this Section shall be regulations and standards promulgated pursuant thereto license fee of $500. signed by the applicant, verified, and accompanied by a and: (a) is under the medical supervision of one or more Amended by P.A. 81-224, § 1, eff. Jan. 1, 1980. physicians; (b) permits a surgical procedure to be performed only 157-8.6. Issuance of license-RequirementsRenew of by a physician, podiatrist or dentist who at the time is license-Provisional licenses privileged to have his patients admitted by himself or an § 6. Upon receipt of an application for a license, the associated physician and is himself privileged to perform ing reasons: Director may deny the application for any of the follow- surgical procedures in at least one Illinois hospital; and (c) maintains adequate medical records for each patient. (1) Conviction of the applicant, or if the applicant is A license, unless sooner suspended or revoked, shall be a firm, if partnership or association, of any of its members, renewable annually upon approval by the Department and the or a corporation, of any of its officers or directors, of payment of a license fee of $300. Each license shall be of person designated to manage or supervise the facility, or issued only for the premises and persons named in the turpitude, as shown by a certified copy of the record of a felony, or of 2 or more misdemeanors involving moral application and shall not be transferable or assignable. The licenses shall be posted in a conspicuous place on the li- the court of conviction, or, in the case of the conviction censed premises. A placard or registry of all physicians of a misdemeanor by a court not of record, as shown by on staff in the facility shall be centrally located and avail- other evidence, if the Director determines, after investiga- able for inspection to any interested person. The Depart- tion, that such person has not been sufficiently rehabili- ment may, either before or after the issuance of a license, evidence that the moral character of the applicant, or tated to warrant the public trust; or other satisfactory request the cooperation of the State Fire Marshal. The report and recommendations of this agency shall be in manager, or supervisor of the facility is not reputable; writing and shall state with particularity its findings with App. 154 App. 155 respect to compliance or noncompliance with such mini- mum standards, rules and regulations. 157-8.7. Denial, suspension and revocation of license- Notice-Hearings-Subpenas-epositions bulatory surgical treatment center which does not substan- am- The Director may issue a provisional license to any § 7. The Director after notice and opportunity for hear- tially comply with the provisions of this Act and the ing to the applicant or licensee may deny, suspend, or dards, rules and regulations promulgated by virtue thereof stan- revoke a license to open, conduct and maintain an am- provided that he finds that such ambulatory surgical treat- bulatory surgical treatment center in any case in which he or she finds that there has been a substantial failure ment center will undertake changes and corrections which upon completion will render the ambulatory surgical treat. to comply with the provisions of this Act or the standards, ment center in substantial compliance with the provisions rules and regulations established by virtue thereof. of this Act, and the standards, rules and regulations Such notice shall be effected by registered mail or by adopted hereunder, and provided that the health and safe- personal service setting forth the particular reasons for ty of the patients of the ambulatory surgical treatment the proposed action and fixing a date, not less than 15 center will be protected during the period for which such days from the date of such mailing or service, at which provisional license is issued. The Director shall advise the time the applicant or licensee shall be given an oppor- licensee of the conditions under which such provisional li- tunity for a hearing. cense is issued, including the manner in which the facilities A copy of the notice shall be displayed in a conspicuous fail to comply with the provisions of the Act, standards, place adjacent to the license required to be displayed un- rules and regulations, and the time within which the der Section 6 of this Act1 until such time as the Depart- changes and corrections necessary for such ambulatory ment renders its final administrative order. At the end surgical treatment center to substantially comply with this of each fiscal quarter the Department shall prepare and Act, and the standards, rules and regulations of the De- publish a report regarding the status or final disposition partment relating thereto shall be completed. of its actions against licensees or applicants that have Amended by P.A. 81-224, § 1, eff. Jan. 1, 1980. been served with notice regarding a contemplated denial, a refusal to renew or revocation of a license by the De- 157-8.6-1. Abortions-Licensed physicians partment. The report shall identify the facility and the licensee or applicant that are the subject of contemplated § 6.1. Notwithstanding any other provision of this Act, action and summarize the facts and charges that constitute any corporation operating an Ambulatory Surgical Treat- the grounds for such action. The reports shall be conveyed ment Center devoted primarily to providing facilities for to the Governor and the General Assembly and shall be abortion must have a physician, who is licensed to practice made available to the general public free of charge. Copies medicine in all of its branches and is actively engaged in of such reports shall be available for distribution through the practice of medicine at the Center, on the board of local health departments and regional and sub-regional of- directors as a condition to licensure of the Center. fices of the Department. Added by P.A. 81-771, § 1, eff. Jan. 1, 1980. The hearing shall be conducted by the Director or by an individual designated in writing by the Director as Hearing Officer to conduct the hearing. On the basis of any such hearing, or upon default of the applicant or li- censee, the Director shall make a determination specify- App. 156 App. 157 ing his or her findings and conclusions. A copy of such Any circuit court of this State, upon the application of determination shall be sent by registered mail or served the Director, or upon the application of any other party personally upon the applicant or licensee. the proceeding, may, in its or his or her discretion, The procedure governing hearings authorized by this compel to the attendance of witnesses, the production of Section shall be in accordance with rules promulgated by books, papers, records or memoranda and the giving of the Department. A full and complete record shall be kept testimony before the Director or Hearing Officer conduct- of all proceedings, including the notice of hearing, com- ing an investigation or holding a hearing authorized by plaint, and all other documents in the nature of pleadings, this Act, by an attachment for contempt or otherwise, in written motions filed in the proceedings, and the report the same manner as production of evidence may be com- and orders of the Director and Hearing Officer. All testi- pelled before the court. mony shall be reported but need not be transcribed unless The Director or Hearing Officer, or any party in an in- the decision is sought to be reviewed pursuant to the Ad- vestigation or hearing before the Department, may cause ministrative Review Law.2 A copy or copies of the tran- the depositions of witnesses within the State to be taken script may be obtained by any interested party on pay- in the manner prescribed by law for like depositions in ment of the cost of preparing such copy or copies. civil actions in courts of this State, and to that end com- The Director or Hearing Officer, shall upon his or her pel the attendance of witnesses and the production of own motion, or on the written request of any party to books, papers, records, or memoranda. the proceeding, issue subpoenas requiring the attendance Amended by P.A. 82-783, Art. XI, $ 201, eff. July 13, and the giving of testimony by witnesses, and subpoenas 1982; P.A. 83-334, $ 87, eff. Sept. 14, 1983; P.A. 83-345, duces tecum requiring the production of books, papers, § 67, eff. Sept. 14, 1983. records or memoranda. All subpoenas and subpoenas duces tecum issued under the terms of this Act may be 1 Paragraph 157-8.6 of this chapter. served by any person of legal age. The fees of witnesses 2 Chapter 110, 9 3-101 et seq. for attendance and travel shall be the same as the fees P.A. 83-334, in the first paragraph, inserted "or she"; in the sec- of witnesses before the Circuit Court of this State, such ond paragraph, substituted "15" for "fifteen"; in the fourth para- fees to be paid when the witness is excused from further graph, inserted "or her"; in the sixth paragraph, inserted "or her", substituted "above stated" for "aforesaid", and, at the end of the attendance. When the witness is subpoenaed at the in- sixth paragraph, substituted "by a circuit court" for "out of a stance of the Director or Hearing Officer, such fees shall court of record"; in the seventh paragraph, following "State", be paid in the same manner as other expenses of the De- deleted "or any judge thereof, either in term time or vacation", partment, and when the witness is subpoenaed at the in- and, also in the seventh paragraph, inserted "or her", and sub- stituted "the" for "said" the last place it appears in the seventh stance of any other party to any such proceeding the Department may require that the cost of service of the paragraph. P.A. 83-345, in the second paragraph, substituted "15" for "fif- subpoena or subpoena duces tecum and the fee of the wit- teen"; in the sixth paragraph, inserted "or her", and substituted ness be borne by the party at whose instance the witness "legal" for "full"; in the last sentence of the sixth paragraph, in- was summoned. In such case, the Department in its dis- serted "so" and "circuit", and, following "issued", deleted "as cretion, may require a deposit to cover the cost of such aforesaid", and, following "court", deleted "of record"; in the sev- service and witness fees. A subpoena or subpoena duces enth paragraph, following "State", deleted "or any judge thereof, tecum SO issued as above stated shall be served in the either in term time or vacation"; in the seventh paragraph, pre- ceding "discretion", deleted "or his"; and substituted "the" for same manner as a subpoena issued by a circuit court. "said" the last place it appears in the seventh paragraph. App. 158 App. 159 Final legislative action, 83rd General Assembly: (b) No public funds shall be expended for the care or P.A. 83-334-June 20, 1983 treatment of any patient in an ambulatory surgical treat- P.A. 83-345-June 20, 1983 ment center which has failed to file the financial state- See Ill.Rev.Stat. ch. 1, 9 1105 as to the effect of (1) more than ment required by this Section, and no public funds shall one amendment of a section at the same session of the General be paid to or on behalf of a facility which has failed to Assembly or (2) two or more acts relating to the same subject file a statement. matter enacted by the same General Assembly. (c) The Director shall promulgate regulations for the filing of financial statements, and shall provide in these 157-8.7a. Statement or ownership regulations for forms, information required, intervals and § 7a. (a) As a condition of the issuance or renewal of dates of filing, and such other provisions as he may deem the license of any ambulatory surgical treatment center, necessary. Regulations shall be published in sufficient time the applicant shall file a statement of ownership. The ap- to permit those licensees who must first file financial plicant shall agree to update the information required in statements time in which to do so. the statement of ownership every 6 months from the in- (d) The Director shall seek the advice and comments itial date of filing. of other State and Federal agencies which require the (b) The statement of ownership shall include the follow- submission of financial data from facilities licensed under ing: this Act and shall incorporate the information require- (1) The name, telephone number and occupation of ments of these agencies into the forms it adopts or issues every person who has entered into a contract to manage under this Act and shall otherwise coordinate its regula- or operate or who owns or controls, directly or indirect- tions with the requirements of these agencies so as to ly, any of the shares of stock of, or any other financial impose the least possible burden on licensees. No other interest in, the facility which is the subject of the applica- State agency may require submission of financial data tion or license, and the percentage of such interest; and except as expressly authorized by law or as necessary to meet requirements of federal law or regulation. In- (2) The address of any facility, wherever located, any formation obtained under this Section shall be made avail- financial interest in which is owned or controlled, direct- able, upon request, by the Department to any other State ly or indirectly, by the applicant, if the facility is required agency or legislative commission to which such informa- to be licensed if it were located in this State. tion is necessary for investigations or to execute the in- Added by P.A. 81-224, § 1, eff. Jan. 1, 1980. tent of State or Federal law or regulation. Added by P.A. 81-224, § 1, eff. Jan. 1, 1980. 157-8.7b. Financial statements § 7b. (a) Each licensee shall file an attested financial 157-8.8. Construction, alterations or additions to treatment statement with the Department by July 1, 1980 and at centers-Approval by Department times thereafter as required. An audited financial state- § 8. Before commencing construction of new facilities ment may be required of a particular facility, if the Direc- or specified types of alteration or additions to an existing tor determines that additional information is needed. ambulatory surgical treatment center, architectural draw- ings and specifications therefor shall be submitted to the Department for review and approval. Final approval of App. 160 App. 161 the drawings and specifications for compliance with design lated to the patients, unless continued treatment of any and construction standards shall be obtained from the given patient is necessary to protect his or her health or Department before the alteration, addition, or new con- life. A written order setting forth the grounds on which struction is begun. any action under this Section is based shall be served on the licensee within 24 hours after such action is taken. 157-8.9. Inspections and investigations-Confidentiality of Any licensee whose ambulatory surgical treatment center information has been closed may, within 10 days thereafter, by writ- ten notice, request that the Director conduct a hearing § 9. The Department shall make or cause to be made and a reinspection under the provisions of this Act. If a such inspections and investigations as it deems necessary subsequent inspection discloses that the violations of this but in no case less than 4 inspections of any licensed facil- Act or rules, regulations or standards have been abated, ity in a fiscal year. Information received by the Depart- the Director shall cancel the order of closing and permit ment through filed reports, inspection, or as otherwise patients to be treated therein. The remedies provided in authorized under this Act shall not be disclosed publicly this Section are in addition to and not exclusive of any in such manner as to identify individual patients, except other remedy provided by law. to another State agency for purposes of investigation of professional or business practices in a licensed ambulatory Added by P.A. 81-224, § 1, eff. Jan. 1, 1980. surgical treatment center, which State agency shall not 1 Paragraph 157-8.12 of this chapter. disclose such individual patient information publicly. Every facility licensed under this Act and any premises 157-8.9b. Complaints-Ambulatory surgical treatment center proposed to be conducted as a facility by an applicant for a license shall be open at all reasonable times to an in- § 9b. The Department shall establish by rule a proce- spection authorized in writing by the Director. No notice dure for receiving and investigating complaints regarding need be given to any person prior to any inspection. any ambulatory surgical treatment center or any physi- cian practicing in any such facility. Amended by P.A. 81-1509, Art. I, § 69, eff. Sept. 26, 1980. Added by P.A. 81-224, $ 1, eff. Jan. 1, 1980. Article I of P.A. 81-1509 was the 1980 Combining Revisory Act, which resolved multiple actions of the 81st General Assembly through P.A. 81-1224. 157-8.10. Standards, rules and regulations-Construction- Personnel-Equipment-Facilities, programs and services 157-8.9a. Closings-Orders-Hearings and reinspections § 10. The Department shall prescribe and publish mini- § 9a. Whenever an inspection of any ambulatory surgi- mum standards, rules and regulations necessary to imple- cal treatment center discloses that the continued opera- ment the provisions of this Act which shall include, but tion of such facility constitutes an imminent and serious not be limited to: menace to the health or safety of the patients thereof, (a) construction of the facility including, but not limited or in the event of a conviction of a licensee under Sec- to, plumbing, heating, lighting, and ventilation which shall tion 12 of this Act,1 the inspector is authorized to immedi- ensure the health, safety, comfort and privacy of patients ately close such facility. Once the facility has been closed, and protection from fire hazard; the personnel employed there shall cease any activity re- App. 162 App. 163 (b) number and qualifications of all personnel, including Amended by P.A. 82-783, Art. XI, $ 201, eff. July 13, administrative and nursing personnel, having reponsibility 1982. for any part of the care provided to the patients; 1 Chapter 110, 9 3-101 et seq. (c) equipment essential to the health, welfare and safety 2 Chapter 110, 1 3-101. of the patients; and (d) facilities, programs and services to be provided in 157-8.12. Violations-Penalties connection with the care of patients in ambulatory surgical treatment centers. $ 12. Any person opening, conducting or maintaining an ambulatory surgical treatment center without a license issued pursuant to this Act shall be guilty of a business 157-8.10a. Administrative Procedure Act-Application offense punishable by a fine of $10,000 and each day's $ 10a. The provisions of "The Illinois Administrative violation shall constitute a separate offense. Any person Procedure Act", approved September 22, 1975,1 are here- opening, conducting or maintaining an ambulatory surgical by expressly adopted and shall apply to all administrative treatment center who violates any other provision of this rules and procedures of the Department of Public Health Act shall be guilty of a business offense punishable by under this Act, except that in case of conflict between a fine of not more than $10,000. "The Illinois Administrative Procedure Act" and this Act Amended by P.A. 81-224, § 1, eff. Jan. 1, 1980. the provisions of this Act shall control, and except that Section 5 of the Illinois Administrative Procedure Act2 157-8.13. Violation of Act or rules and regulations as relating to procedures for rule-making does not apply to the adoption of any rule required by federal law in con- nuisance-Injunction nection with which the Department is precluded by law § 13. The operation or maintenance of an ambulatory from exercising any discretion. surgical treatment center in violation of this Act or of the Rules and Regulations promulgated by the Depart- Added by P.A. 79-1347, $ 17, eff. July 1, 1977. ment is declared a public nuisance inimical to the public 1 Chapter 127, 1 1001 et seq. welfare. The Director of the Department, in the name of 2 Chapter 127, 1 1005. the People of the State, through the Attorney General or the State's Attorney of the county in which the viola- tion occurs, may, in addition to other remedies herein pro- 157-8.11. Review under Administrative Review Law vided, bring action for an injunction to restrain such viola- § 11. Whenever the Department refuses to grant, or tion or to enjoin the future operation or maintenance of revokes or suspends a license to open, conduct or maintain any such ambulatory surgical treatment center. an ambulatory surgical treatment center, the applicant or licensee may have such decision judicially reviewed. The 157-8.14. Licensing Board-Appointment-Qualifications- provisions of the Administrative Review Law¹ and the Term-Vacancy-Expenses-Meetings-Duties rules adopted pursuant thereto shall apply to and govern all proceedings for the judicial review of final administra- § 14. The Governor shall appoint an Ambulatory Sur- tive decisions of the Department hereunder. The term gical Treatment Center Licensing Board composed of 12 "administrative decisions" is defined as in Section 3-101 persons. Four members shall be practicing physicians; one of the Code of Civil Procedure.² member shall be a practicing podiatrist; one member shall App. 164 App. 165 be a dentist who has been licensed to perform oral sur- 157-8.15. Severability of invalid provisions gery; one member shall be an Illinois registered profes- § 15. If any provision of this Act or the application sional nurse who is employed in an ambulatory surgical thereof to any person or circumstance shall be held in- treatment center; one member shall be a person actively valid, such invalidity shall not affect the provisions of ap- engaged in the supervision or administration of a health plication of the Act which can be given effect without the facility; and 4 members shall represent the general public invalid provision or application, and to this end the pro- and shall have no personal economic interest in any insti- visions of the Act are declared to be severable. tution, place or building licensed pursuant to this Act. In making Board appointments, the Governor shall give con- sideration to recommendations made through the Director 157-8.16. Effective date by appropriate professional organizations. § 16. This Act shall take effect upon its becoming a Each member shall hold office for a term of 3 years and law. the terms of office of the members first taking office shall expire, as designated at the time of appointments, 3 at the end of the first year, 3 at the end of the second year, and 6 at the end of the third year, after the date of ap- pointment. The term of office of each original appointee shall commence October 1, 1973; and the term of office of each successor shall commence on October 1 of the year in which his predecessor's term expires. Any member ap- pointed to fill a vacancy occurring prior to the expiration of the term for which his predecessor was appointed shall be appointed for the remainder of such term. Board mem- bers, while serving on business of the Board shall receive actual and necessary travel and subsistence expenses while SO serving away from their places of residence. The Board shall meet as frequently as the Director deems necessary, but not less than once a year. Upon request of 3 or more members, the Director shall call a meeting of the Board. The Board shall advise and consult with the Department in the administration of this Act, provided that no rule, regulation or standard shall be adopted by the Depart- ment concerning the operation of ambulatory surgical treatment centers licensed under this Act which has not had prior approval of the Ambulatory Surgical Treatment Center Licensing Board. Amended by P.A. 79-339, § 1, eff. Oct. 1, 1975. App. 166 App. 167 APPENDIX J 1153. Definitions § 3. As used in this Act: "Health care facilities" means and includes the following facilities and organizations: Health Facilities Planning Act, 111½ III. Rev. Stat. 11 1151, et seq. 1. An ambulatory surgical treatment center required to be licensed pursuant to the "Ambulatory Surgical Treat- ILLINOIS HEALTH FACILITIES PLANNING ACT ment Center Act", approved July 19, 1973, as amended;¹ AN ACT to provide for the planning of Illinois health 2. An institution, place, building, or agency required facilities. P.A. 78-1156, approved and eff. Aug. 27, 1974. to be licensed pursuant to the "Hospital Licensing Act", approved July 1, 1953, as amended;2 1151. Short title 3. Any institution required to be licensed pursuant to $ 1. This Act shall be known and may be cited as the the "Nursing Home Care Reform Act of 1979", approved Illinois Health Facilities Planning Act. August 23, 1979, as amended;3 1152. Purpose of Act 4. Hospitals, nursing homes, ambulatory surgical treat- § 2. The purpose of this Act is to establish a procedure ment centers or kidney disease treatment centers, or designed to reverse the trends of increasing costs of health maintenance organizations maintained by the State health care resulting from unnecessary construction or or any department or agency thereof; modification of health care facilities. Such procedure shall 5. Kidney disease treatment centers, including a free- represent an attempt by the State of Illinois to improve standing hemodialysis unit; and the financial ability of the public to obtain necessary 6. Any health maintenance organization required to be health services, and to establish an orderly and compre- operated pursuant to the "Health Maintenance Organiza- hensive health care delivery system which will guarantee tion Act", approved August 27, 1974, as now or hereafter the availability of quality health care to the general public. amended,4 and which: This Act shall establish a procedure (1) which requires (A) is a qualified health maintenance organization under a person establishing, constructing or modifying a health Section 1310(d) of the Public Health Services Act;5 or care facility, as herein defined, to have the qualifications, background, character and financial resources to adequate- (B) (i) provides or otherwise makes available to enrolled ly provide a proper service for the community; (2) that participants health care services, including at least the promotes through the process of recognized local and area- following basic health care services: usual physician ser- wide health facilities planning, the orderly and economic vices, hospitalization, laboratory, x-ray, emergency and development of health care facilities in the State of Illi- preventive services, and out of area coverage; (ii) is com- nois that avoids unnecessary duplication of such facilities; pensated (except for co-payments) for the provision of the (3) that promotes planning for and development of health basic health care services listed in clause (i) to enrolled care facilities needed for comprehensive health care es- participants by a payment which is paid on a periodic pecially in areas where the health planning process has basis without regard to the date the health care services identified unmet needs; and (4) that carries out these pur- are provided and which is fixed without regard to the fre- poses in coordination with the Agency and the comprehen- quency, extent, or kind of health service actually provided; sive State health plan developed by that Agency. and (iii) provides physicians' services primarily (I) direct- Amended by P.A. 80-941, § 1, eff. Sept. 22, 1977. App. 168 App. 169 ly through physicians who are either employees or part- in any activity which involves the providing, administering ners of such organization, or (II) through arrangements or financing of any type of health care facility, or (d) who with individual physicians or one or more groups of physi- is or ever has been a member of the immediate family cians (organized on a group practice or individual prac- of the person defined by (a), (b), or (c). tice basis). "State Board" means the Health Facilities Planning No federally owned facility shall be subject to the pro- Board. visions of this Act, nor facilities used solely for healing "Construction or modification" means the establishment, by prayer or spiritual means. erection, building, alteration, reconstruction, moderniza- With the exception of those health care facilities specifi- tion, improvement, extension, discontinuation, change of cally included in this Section, nothing in this Act shall ownership, of or by a health care facility, or the purchase be intended to include facilities operated as a part of the or acquisition by or through a health care facility of equip- practice of a physician or other licensed health care pro- ment or service for diagnostic or therapeutic purposes or fessional, whether practicing in his individual capacity or for facility administration or operation, or any capital ex- within the legal structure of any partnership, medical or penditure made by or on behalf of a health care facility professional corporation, or unincorporated medical or pro- which exceeds the capital expenditure minimum. fessional group. Further, this Act shall not apply to physi- "Establish" means the construction of a health care cians or other licensed health care professional's practices facility or the replacement of an existing facility on an- where such practices are carried out in a portion of a other site. health care facility under contract with such health care facility by a physician or by other licensed health care "Major medical equipment" means medical equipment professionals, whether practicing in his individual capaci- which is used for the provision of medical and other health ty or within the legal structure of any partnership, medi- services and which costs in excess of the capital expen- cal or professional corporation, or unincorporated medical diture minimum, except that such term does not include or professional groups. This Act shall apply to construc- medical equipment acquired by or on behalf of a clinical tion or modification and to establishment by such health laboratory to provide clinical laboratory services if the care facility of such contracted portion which is subject clinical laboratory is independent of a physician's office to facility licensing requirements, irrespective of the party and a hospital and it has been determined under Title responsible for such action or attendant financial obliga- XVIII of the Social Security Act6 to meet the require- tion. ments of paragraphs (10) and (11) of Section 1861(s) of such Act.⁷ In determining whether medical equipment has a "Person" means any one or more natural persons, legal value in excess of the capital expenditure minimum, the entities, governmental bodies other than federal, or any value of studies, surveys, designs, plans, working draw- combination thereof. ings, specifications, and other activities essential to the "Consumer" means any person other than a person (a) acquisition of such equipment shall be included. whose major occupation currently involves or whose of- "Capital Expenditure" means an expenditure: (A) made ficial capacity within the last 12 months has involved the by or on behalf of a health care facility (as such a facil- providing, administering or financing of any type of health ity is defined in this Act); and (B) which under generally care facility, (b) who is engaged in health research or the accepted accounting principles is not properly chargeable teaching of health, (c) who has a material financial interest as an expense of operation and maintenance, or is made App. 170 App. 171 to obtain by lease or comparable arrangement any facility "Local health planning organization" means those local or part thereof or any equipment for a facility or part; health planning organizations that are designated as such and which exceeds the capital expenditure minimum. by the areawide health planning organization of the appro- For the purpose of this paragraph, the cost of any priate area. studies, surveys, designs, plans, working drawings, speci- "Physician" means a person licensed to practice in ac- fications, and other activities essential to the acquisition, cordance with the Medical Practice Act, as amended.9 improvement, expansion, or replacement of any plant or equipment with respect to which an expenditure is made "Licensed health care professional" means a person shall be included in determining if such expenditure ex- licensed to practice a health profession under pertinent ceeds the capital expenditures minimum. Donations of licensing statutes of the State of Illinois. equipment or facilities to a health care facility which if "Director" means the Director of the Illinois Depart- acquired directly by such facility would be subject to ment of Public Health. review under this Act shall be considered capital expen- ditures, and a transfer of equipment or facilities for less "Agency" means the Illinois Department of Public than fair market value shall be considered a capital ex- Health. penditure for purposes of this Act if a transfer of the "Comprehensive health planning" means health planning equipment or facilities at fair market value would be sub- concerned with the total population and all health and as- ject to review. sociated problems that affect the well-being of people and "Capital expenditure minimum" means $400,000 for ma- that encompasses health services, health manpower, and jor medical equipment and $600,000 for all other capital health facilities; and the coordination among these and expenditures, both of which shall be annually adjusted to with those social, economic, and environmental factors that reflect the increase in construction costs due to inflation. affect health. "Areawide" means a major area of the State delineated Amended by P.A. 82-745, § 1, eff. May 7, 1982; P.A. on a geographic, demographic, and functional basis for 83-333, $ 63, eff. Sept. 14, 1983. health planning and for health service and having within 1 Paragraph 157.8-1 et seq. of this chapter. it one or more local areas for health planning and health 2 Paragraph 142 et seq. of this chapter. service. The term "region", as contrasted with the term 3 Paragraph 4151-101 et seq. of this chapter. "subregion", and the word "area" may be used synony- mously with with term "areawide". 4 Paragraph 1401 et seq. of this chapter. 5 42 U.S.C.A. § 300e-9. "Local" means a subarea of a delineated major area that 6 42 U.S.C.A. § 1395 et seq. on a geographic, demographic, and functional basis may 7 42 U.S.C.A. § 1395x. be considered to be part of such major area. The term 8 42 U.S.C.A. § 300k et seq. "subregion" may be used synonymously with the term "local". 9 Chapter 111, 1 4401 et seq. "Areawide health planning organization" or "Compre- hensive health planning organization" means the health 1153.1. Major medical equipment-Acquisition systems agency designated by the Secretary, Department § 3.1. Until January 1, 1984 and not thereafter, any of Health, Education, and Welfare, pursuant to federal person proposing to acquire major medical equipment (as Public Law 93-641,8 or any successor agency, defined in this Act) is subject to the provisions of this App. 172 App. 173 Act regarding obtaining a permit or exemption. The pro- members individuals familiar with community health needs visions of this Section shall be in effect until January 1, but whose interest in the operation, construction or utiliza- 1984, or the repeal of Public Law 93-641, as amended, tion of health care facilities are derived from factors other whichever shall come first. than those related to his profession, business, or economic Added by P.A. 82-745, § 1, eff. May 7, 1982. gain, and who represent, so far as possible, different geo- 1 42 U.S.C.A. $ 300k et seq. graphic areas of the State. Not more than 7 of the ap- pointments shall be of the same political party. Paragraph effective until Jan. 1, 1984, or the repeal The Directors of the Illinois Departments of Public Aid, of the National Health Planning and Resources De- Mental Health and Public Health, or their designated rep- velopment Act of 1974 (42 U.S.C.A. § 300k et seq.). resentatives, shall serve as ex-officio, non-voting members of the State Board. 1154. Health Facilities Planning Board-Membership-Ap- Of those appointed by the Governor as voting members, pointment-Term-Compensation-Quorum each member shall hold office for a term of 3 years: pro- § 4. There is created the Health Facilities Planning vided, that any member appointed to fill a vacancy oc- Board, which shall perform such functions as hereinafter curring prior to the expiration of the term for which his described in this Act. predecessor was appointed shall be appointed for the re- The State Board shall consist of 13 voting members, in- mainder of such term and the term of office of each suc- cluding: 7 consumer members; one member representing cessor shall commence on July 1 of the year in which his the commercial health insurance industry in Illinois; one predecessor's term expires. In making original appoint- member representing the hospital service corporations in ments to the State Board, the Governor shall appoint 5 Illinois; one member who is actively engaged in the field members for a term of one year, 5 for a term of 2 years, of hospital management; one member who is a professional and 3 for a term of 3 years, and each of these terms of nurse registered in Illinois; one member who is a physi- office shall commence on July 1, 1974. Each member shall cian in active private practice licensed in Illinois to prac- hold office until his successor is appointed and qualified. tice medicine in all of its branches; and one member who No member shall serve more than 3 consecutive 3-year is actively engaged in the field of skilled nursing or inter- terms, except for those members who are ex-officio, non- mediate care facility management. voting members. The State Board shall be appointed by the Governor, State Board members, while serving on business of the with the advice and consent of the Senate. In making the State Board, shall receive actual and necessary travel and appointments, the Governor shall give consideration to subsistence expenses while so serving away from their recommendations made by (1) the professional organiza- places of residence. In addition, while serving on business tions concerned with hospital management for the hospital of the State Board, each member shall receive compen- management appointment and (2) professional organiza- sation of $150 per day for each day served at regular or tions concerned with long term care facility management special meetings of the State Board or at committee meet- for the long term care facility management appointment ings approved by the Chairman of the State Board, ex- and (3) professional medical organizations for the physi- cept that such compensation shall not exceed $7,500 in cian appointment and (4) professional nursing organizations any one year for any member. for the nurse appointment, and shall appoint as consumer App. 174 App. 175 The State Board shall provide for its own organization obtain a permit for any purpose under this Act until the and procedures, including the selection of a Chairman and State health facilities plan referred to in paragraph (4) such other officers as deemed necessary. The Director, of Section 12 of this Act1 has been approved and adopted with concurrence of the State Board, shall name as full- by the State Board subsequent to public hearings hav- time Executive Secretary of the State Board, a person ing been held thereon. qualified in health care facility planning and in administra- A permit or exemption shall be obtained prior to the tion. The Agency shall provide administrative and staff acquisition of major medical equipment or to the construe- support for the State Board. The State Board shall ad- tion or modification of a health care facility which: vise the Director of its budgetary and staff needs and con- sult with the Director on annual budget preparation. (a) requires a total capital expenditure in excess of the capital expenditure minimum; or The State Board shall meet at least once each quarter, or as often as the Chairman of the State Board deems (b) substantially changes the scope or changes the fune- necessary, or upon the request of a majority of the mem- tional operation of the facility; or bers. (c) changes the bed capacity of a health care facility Seven members of the State Board shall constitute a by increasing or decreasing the total number of beds or quorum. The affirmative vote of 7 of the members of the by distributing beds among various categories of service State Board shall be necessary for any action requiring or by relocating beds from one physical facility or site a vote to be taken by the State Board. A vacancy in the to another by more than 10 beds or more than 10% of membership of the State Board shall not impair the right total bed capacity as defined by the State Board, which- of a quorum to exercise all the rights and perform all the ever is less, over a 2 year period. duties of the State Board as provided by this Act. A permit shall be valid only for the defined construction Amended by P.A. 81-149, $ 1, eff. Jan. 1, 1980. or modifications, site, amount and person named in the application for such permit and shall not be transferable or assignable. A permit shall be valid until such time as 1155. Permits or exemptions-Construction, modification or the project has been completed, provided that (a) obliga- establishment of health care facilities-Acquisition of tion of the project occurs within 12 months following issu- major medical equipment ance of the permit except for major construction projects § 5. After effective dates set by the State Board, no such obligation must occur with 18 months following is- person shall construct, modify or establish a health care suance of the permit; and (b) the project commences and facility or acquire major medical equipment without first proceeds to completion with due diligence. Major construc- obtaining a permit or exemption from the State Board. tion projects, for the purposes of this Act, shall include The State Board shall set effective dates applicable to all but are not limited to: projects for the construction of new or to each classification or category of health care facilities buildings; additions to existing facilities; modernization and applicable to all or each type of transaction for which projects whose cost is in excess of $1,000,000 or 10% of a permit is required. Varying effective dates may be set, the facilities' operating revenue, whichever is less; and providing the date or dates SO set shall apply uniformly such other projects as the State Board shall define and statewide. prescribe pursuant to this Act. The State Board may re- Notwithstanding any effective dates established by this new that permit for an additional reasonable length of Act or by the State Board, no person shall be required to time upon showing by the applicant that additional time App. 176 App. 177 is required to complete the establishment, construction or The State Board shall establish by regulation the proce- modification of the health care facility or acquisition of dures and requirements regarding issuance of exemptions. major medical equipment. Such exemptions shall be limited to those transactions specified by Title XV of the federal Public Health Services Persons who otherwise would be required to obtain a Act1 and shall include acquisitions of existing health care permit shall be exempt from such requirement if the State facilities by any person. Board finds that with respect to establishing a new facility or construction of new buildings or additions or modifica- All applications shall be signed by the applicant and tions to an existing facility, final plans and specifications shall be verified by any 2 officers thereof. for such work have prior to October 1, 1974, been sub- Upon receipt of an application for a permit, the State mitted to and approved by the Department of Public Board shall approve and authorize the issuance of a per- Health in accordance with the requirements of applicable mit if it finds (1) that the applicant is fit, willing, and able laws. Such exemptions shall be null and void after Decem- to provice a proper standard of health care service for ber 31, 1979 unless binding construction contracts were the community with particular regard to the qualification, signed prior to December 1, 1979 and unless construction background and character of the applicant, (2) that eco- has commenced prior to December 31, 1979. Such exemp- nomic feasibility is demonstrated in terms of effect on the tions shall be valid until such time as the project has been existing and projected operating budget of the applicant completed provided that the project proceeds to comple- and of the health care facility; in terms of the applicant's tion with due diligence. ability to establish and operate such facility in accordance The acquisition by any person of major medical equip- with licensure regulations promulgated under pertinent ment that will not be owned by or located in a health state laws; and in terms of the projected impact on the care facility and that will not be used to provide services total health care expenditures in the facility and communi- to inpatients of a health care facility shall be exempt from ty, (3) that safeguards are provided which assure that the review provided that a notice is filed in accordance with establishment, construction or modification of the health exemption requirements. care facility or acquisition of major medical equipment is consistent with the public interest, and (4) that the pro- Amended by P.A. 82-745, § 1, eff. May 7, 1982. posed project is consistent with the orderly and economic 1 Paragraph 1162 of this chapter. development of such facilities and equipment and is in ac- cord with standards, criteria, or plans of need adopted 1156. Application for permit or exemption-Exemption and approved pursuant to the provisions of Section 12 of this Act.2 regulations § 6. An application for a permit or exemption shall be Amended by P.A. 82-745, $ 1, eff. May 7, 1982. made to the State Board upon forms provided by the 1 42 U.S.C.A. § 300u et seq. State Board. This application shall contain such informa- 2 Paragraph 1162 of this chapter. tion as the State Board deems necessary. Such applica- tion shall include affirmative evidence on which the Direc- tor may make the findings required under this Section 1156.1. Submission of applications-Timetable and upon which the State Board may make its decision $ 6.1. The State Board shall require applications to be on the approval or denial of the permit or exemption. submitted in accordance with a timetable established by the State Agency, and review all completed applications App. 178 App. 179 pertaining to similar types of services, facilities, or equip- Recognition of these organizations with regard to health ment affecting the same health service area in relation facilities planning, including establishment of the criteria to each other (but no less often than twice a year). for such recognition, shall be the responsibility of the State Board, as provided elsewhere in this Act. The State Board shall specify when applications may be exempted from this timetable and from being reviewed The Agency is authorized to make grants-in-aid or to in relation to each other. furnish direct services to organizations in the development of health facilities planning capability, as a part of other The provisions of this Section shall be in effect until financial and service assistance which the Agency is em- January 1, 1984, or the repeal of Public Law 93-641, as powered and required to provide in support of health plan- amended,¹ whichever shall come first. ning organizations. Added by P.A. 82-745, § 1, eff. May 7, 1982. Upon receipt of an application for a permit to establish, 1 42 U.S.C.A. $ 300k et seq. construct or modify a health care facility, the Agency shall Paragraph effective until Jan. 1, 1984, or the repeal notify the applicant in writing within 10 working days of the National Health Planning and Resources De- either that the application is complete or the reasons why velopment Act of 1974 (42 U.S.C.A. § 300k et seq.). the application is not complete. If the application is com- plete, the Agency shall notify affected persons of the beginning of a review and the review time cycle for the 1157. Cooperation of other age. ies in obtaining informa- purposes of this Act shall begin on the date this notifica- tion relating to applications tion is mailed. § 7. The Director of the State Board may request the Upon notifying affected persons of the beginning of a cooperation of county and multiple-county health depart- review of an application for a permit, a complete copy ments, municipal boards of health, and other governmental of such application shall be transmitted to the areawide and nongovernmental agencies in obtaining information health planning organization serving the area or communi- and in conducting investigations relating to applications ty where the health care facility or major medical equip- for permits. ment is proposed to be acquired, established, constructed Amended by P.A. 80-941, § 1, eff. Sept. 22, 1977. or modified. The Agency shall also transmit a complete copy of such application to any reasonably contiguous areawide health planning organization. The Agency shall 1158. Areawide health planning organizations afford a reasonable time as established by the State § 8. The Agency shall assist communities and regions Board, but not to exceed 120 days in length, for the throughout the State to establish areawide health planning areawise planning organizations' review of the application. organizations and, in particular, shall assist such organiza- After reviewing the application, each recognized areawide tions to develop health care facilities planning which meets planning organization shall certify its findings to the State the criteria for recognition thereof. Areawide health plan- Board as to whether or not the application is approved ning organizations may be recognized to do health facilities or disapproved in accordance with standards, criteria or planning by providing this component of health planning plans of need adopted and approved by the recognized within the organization or by contracting with a special- areawide health planning organization pursuant to its rec- purpose health planning organization that meets the ognition by the State Board for health care facilities plan- criteria for health facilities planning. ning. The 120-day period shall begin on the day the ap- App. 180 App. 181 plication is found to be substantially complete, as that the Agency shall be afforded a reasonable time, but not term is defined by the State Board. During such 120-day to exceed 120 days, for its review and finding thereon. period, the applicant may request an extension. An ap- The Agency shall submit its review and finding to the plicant may modify the application at any time prior to State Board for its approval or denial of the permit. a final administrative decision on the application. When an application for a permit is initially reviewed Upon its receipt of an application, the areawide health by a recognized areawide health planning organization or planning organization or the Agency, as the case may be, the Agency, as herein provided, the organization or the may submit a copy of such application to the federally-rec- Agency, as the case may be, shall afford an opportunity ognized professional standards review organizátion, if any, for a public hearing within a reasonable time after receipt and appropriate local health planning organization, if any, of the complete application, not to exceed 90 days. Notice existing in the area where the proposed project is to oc- of such hearing shall be made promptly by certified mail cur. Such organizations may review the application for a to the applicant and, within 10 days of the hearing, by permit and submit, within 30 days from the receipt of the publication in a newspaper of general circulation in the application, a finding to the agency or to the areawide area or community to be affected. Such hearing shall be health planning organization, as the case may be. A re- conducted in the area or community where the proposed view and finding by a federally-recognized professional project is to occur, and shall be for the purpose of allow- standards review organization must be relevant to the ac- ing the applicant and any interested person to present tivities for which such organization is recognized, and shall public testimony concerning the approval, denial, renewal be considered by the Agency or the areawide health plan- or revocation of the permit. All interested persons attend- ning organization, as the case may be, in its review of ing such hearing shall be given reasonable opportunity to the application. present their views or arguments in writing or orally, and The State Board shall prescribe and provide the forms a record of all such testimony shall accompany any recom- upon which the review and finding of the organization mendation of the Agency or the recognized areawide shall be made. The recognized areawide health planning health planning organization for the issuance, denial, rev- organizations shall submit their review and finding to the ocation or renewal of a permit to the State Board. The Agency for its finding on the application and transmittal State Board shall promulate reasonable rules and regula- to the State Board for its consideration of denial or ap- tions governing the procedure and conduct of such hear- proval. Whenever the State Board renders a decision on ings. an application which is contrary to the finding of the Amended by P.A. 82-745, $ 1, eff. May 7, 1982. areawide health planning organization or agency thereon, 1 Paragraph 1160 of this chapter. that organization shall be provided a written detailed statement of the reasons for the inconsistency and shall be afforded an opportunity for a hearing before a hear- 1159. Certificate of recognition-Application-Hearing ing officer, who is appointed by the State Board. Such § 9. An application for a certificate of recognition for hearing shall be conducted in accordance with the provi- an areawide health planning organization for health facili- sions specified in Section 10 of this Act.¹ ties planning shall be made to the State Board upon forms If there is no areawide health planning organization in provided by it and shall contain evidence that standards, the area where the proposed establishment, construction criteria and plans of need have been adopted and approved or modification of a health care facility is to occur, then by the organization for health care facilities planning for App. 182 App. 183 the area which the applicant intends to serve and such Agency pursuant to the public hearing in conjunction with other information as may reasonably be required. All such the recommendation of the Agency for the approval, de- applications for a certificate of recognition shall be sub- nial or revocation of the certificate of recognition. mitted to the State Board and evaluated by the Agency. Amended by P.A. 81-149, $ 1, eff. Jan. 1, 1980. If the Agency finds that the applicant for a certificate of recognition for health facilities planning meets the criteria established under this Act, it shall submit its 1160. Denial of application for permit or renewal thereof recommendation of approval to the State Board. A certifi- or a certificate of recognition-Appearance-Hearing- cate of recognition shall be approved by the State Board Record-Review under Administrative Review Law-Wit- and shall be valid for such period as the State Board, nesses upon its findings determines that the recognized areawide § 10. When a motion by the State Board, to approve health planning organization continues to comply with the an application for a permit, a renewal thereof or a cer- criteria for recognition. The State Board shall annually tificate of recognition, fails to pass, or when a motion to review the certificate of recognition and afford an oppor- deny an application for permit, a renewal thereof or a cer- tunity for public comment in order to determine that the tificate of recognition, is passed, the applicant or a holder recognized areawide health planning organization continues of a permit, as the case may be, and such other parties to comply with the criteria for recognition. A certificate as the State Board permits, will be given an opportunity of recognition may be revoked by the State Board, follow- to appear before the State Board and present such infor- ing opportunity for appeal and hearing as provided in this mation as may be relevant to the approval of a permit Act. Upon loss of recognition, funds awarded to the area- or certificate or renewal or in resistance of a denial of wide health planning organization by the Agency pursuant the application. to this Act shall be terminated. Subsequent to an appearance by the applicant before When an application for a certificate of recognition of an the State Board or default of such opportunity to appear, areawide health planning organization for health facilities a motion by the State Board to approve an application planning is made to the State Board, the Agency shall for permit, a renewal thereof or a certificate of recogni- conduct a public hearing within a reasonable period after tion which fails to pass or a motion to deny an applica- receipt of the application, not to exceed 90 days. Notice tion for permit, a renewal thereof or a certificate of rec- of such hearing shall be made promptly to the applicant ognition which passes shall be considered denial of the by certified mail and by publication in a newspaper of gen- application for permit, renewal thereof, or certificate of eral circulation in the area where the applicant intends recognition, as the case may be. Such action of denial or to conduct health facilities planning. Such hearings shall an action by the State Board to revoke a permit or a cer- be conducted by the Agency in the area affected, and shall tificate of recognition shall be communicated to the appli- be for the purpose of allowing the applicant and all inter- cant or holder of the permit or certificate of need. Such ested parties to present public testimony concerning the person or organization shall be afforded an opportunity approval, denial or revocation of a certificate of recogni- for a hearing before a hearing officer, who is appointed tion. All interested parties attending such hearing shall by the State Board. A written notice of a request for such be given reasonable opportunity to present their views hearing shall be served upon the Chairman of the State orally or in writing, and a record of such testimony shall Board within 30 days following notification of the deci- be transmitted to the State Board by the Agency. The sion of the State Board. The State Board shall schedule State Board shall consider all testimony submitted by the App. 184 App. 185 a hearing within 30 days thereafter. Following its consid- poena or subpoena duces tecum SO issued shall be served eration of the report of the hearing, or upon default of in the same manner as a subpoena issued out of a court. the party to the hearing, the State Board shall make its Any circuit court of this State upon the application of final determination, specifying its findings and conclusions. the State Board or upon the application of any other party A copy of such determination shall be sent by certified to the proceeding, may, in its discretion, compel the at- mail or served personally upon the party. tendance of witnesses, the production of books, papers, A full and complete record shall be kept of all proceed- records, or memoranda and the giving of testimony before ings, including the notice of hearing, complaint, and all it or its hearing officer conducting an investigation or other documents in the nature of pleadings, written mo- holding a hearing authorized by this Act, by an attach- tions filed in the proceedings, and the report and orders ment for contempt, or otherwise, in the same manner as of the State Board or hearing officer. All testimony shall production of evidence may be compelled before the court. be reported but need not be transcribed unless the deci- The State Board or its hearing officer, or any party to sion is appealed in accordance with Administrative Review a hearing under this Act, may cause the depositions of Law, as now or hereafter amended.¹ A copy or copies of witnesses within the State to be taken in the manner the transcript may be obtained by any interested party prescribed by law for like depositions in civil actions in on payment of the cost of preparing such copy or copies. courts of this State, and to that end compel the attend- The State Board or hearing officer shall upon-its own ance of witnesses and the production of books, papers or or his motion, or on the written request of any party to memoranda. the proceeding who has, in the State Board's or hearing Amended by P.A. 82-783, Art. XI, § 215, eff. July 13, officer's opinion, demonstrated the relevancy of such re- 1982. quest to the outcome of the proceedings, issue subpoenas requiring the attendance and the giving of testimony by 1 Chapter 110, 1 3-101 et seq. witnesses, and subpoenas duces tecum requiring the pro- duction of books, papers, records, or memoranda. The fees 1161. Review under Administrative Review Law of witnesses for attendance and travel shall be the same as the fees of witnesses before the circuit court of this § 11. Any person who is adversely affected by a final State. decision of the State Board may have such decision judi- cially reviewed. The provisions of the Administrative Re- When the witness is subpoenaed at the instance of the view Law, as now or hereafter amended,¹ and the rules State Board, or its hearing officer, such fees shall be paid adopted pursuant thereto shall apply to and govern all in the same manner as other expenses of the Agency, and proceedings for the judicial review of final administrative when the witness is subpoenaed at the instance of any decisions of the State Board. The term "administrative other party to any such proceeding the State Board may, decisions" is as defined in Section 3-101 of the Code of in accordance with the rules of the Agency, require that Civil Procedure.2 the cost of service of the subpoena or subpoena duces tecum and the fee of the witness be borne by the party Amended by P.A. 82-745, $ 1, eff. May 7, 1982; P.A. at whose instance the witness is summoned. In such case, 82-783, Art. XI, $ 215, eff. July 13, 1982; P.A. 82-1057, the State Board in its discretion, may require a deposit Art. II, § 16, eff. Feb. 11, 1983. to cover the cost of such service and witness fees. A sub- 1 Chapter 110, 1 3-101 et seq. 2 Chapter 110, 1 3-101. App. 186 App. 187 Article II of P.A. 82-1057, the 2nd 1982 Revisory Act, resolved (c) The extent of utilization of existing facilities; multiple actions of the 82nd General Assembly through P.A. 82-1016. (d) The availability of facilities which may serve as alternatives or substitutes; 1162. Powers and duties of agency (e) The availability of personnel necessary to the opera- § 12. For purposes of this Act, the Agency shall exer- tion of the facility; cise the following powers and duties: (f) Multi-institutional planning and the establishment of (1) Prescribe, with prior approval of the State Board, multi-institutional systems where feasible; rules, regulations, standards, criteria, procedures or re- views which may vary according to the purpose for which (g) The financial and economic feasibility of proposed a particular review is being conducted or the type of proj- construction or modification; ect reviewed and which are required to carry out the pro- (h) In the case of health care facilities established by visions and purposes of this Act; a religious body or denomination, the needs of the mem- (2) Adopt, with approval of the State Board, procedures bers of such religious body or denomination may be con- for public notice and hearing on all proposed rules, regula- sidered to be public need; and tions, standards, criteria, and plans required to carry out (i) The provisions of Sections 1527, 1531 and 1532, Title the provisions of this Act; XV, of the federal Public Health Services Act.1 (3) Prescribe, with prior approval of the State Board, The health care facility plans which are developed and criteria for recognition for areawide health planning adopted in accordance with this Section shall form the organizations, including, but not limited to, standards for basis for the plan of the State to deal most effectively evaluating the scientific bases for judgments on need and with statewide health needs in regard to health care fa- procedure for making these determinations; cilities. (4) Develop criteria and standards for health care (5) Coordinate with other state agencies having respon- facilities planning, conduct statewide inventories of health sibilities affecting health care facilities, including those of care facilities, and develop health care facility plans which, licensure and cost reporting; upon adoption by the State Board, shall be utilized in the (6) Coordinate with Federal agencies the procedures es- review of applications for permit under this Act. Such tablished by this Act and the required functions to be health facility plans shall be coordinated by the Agen- established by the Agency for purposes of carrying out cy with the health care facility plans areawide health the duties and powers which have been designated to the planning organizations and with other pertinent State Agency under the provisions of Sec. 1122, Title XI, of Plans. the Social Security Act;2 In developing health care facility plans, the Agency (7) Solicit, accept, hold and administer on behalf of the should consider but not be limited to the following: State any grants or bequests of money, securities or prop- (a) The size, composition and growth of the population erty to the Agency for use by the State Board, the Agen- of the area to be served; cy or recognized areawide health planning organizations in the administration of this Act; (b) The number of existing and planned facilities offer- ing similar programs; (8) Charge and collect from the permit applicant an amount determined by the State Board to be a reasonable App. 188 App. 189 application fee for the processing of the application by the (12) Prescribe, with prior approval of the State Board, State Board, the Agency and the appropriate recognized rules, regulations, standards and criteria pertaining to the areawide health planning organization. The State Board granting of permits for construction and modifications shall set the amount by regulation. All fees collected which are emergent in nature and must be undertaken under the provision of this Act shall be deposited with immediately to prevent or correct structural deficiencies the State Treasurer; or hazardous conditions that may harm or injure persons (9) Where local resources are not sufficient, to provide using the facility, as defined in the rules and regulations the necessary technical and financial assistance to recog- of the State Board. This procedure is exempt from public nized areawide health planning organizations to assist in hearing requirements of this Act. the planning which will enable the organization to effec- Amended by P.A. 82-745, § 1, eff. May 7, 1982. tively carry out the functions provided for it in this Act; 1 42 U.S.C.A. §§ 300m-6, 300n and 300n-1. (10) In addition to all powers and duties required of 2 42 U.S.C.A. $ 1320a-1. the Agency and the State Board pertaining to applica- tions for a permit for the construction or modification of health care facilities, the Agency shall prescribe, with the 1163. Investigations of applications for permits and cer- prior approval of the State Board and in consultation with tificates of recognition the recognized areawide health planning organizations, § 13. The Agency or the State Board shall make or procedures for review, standards and criteria which the cause to be made such investigations as it or the State State Board, upon adoption thereof, shall utilize to make Board deems necessary in connection with an application periodic areawide reviews and determinations of the ap- for a permit or an application for a certificate of recogni- propriateness of any existing health services being ren- tion, or in connection with a determination of whether or dered by health care facilities subject to the Act. The not construction or modification which has been com- State Board shall consider recommendations of the area- menced is in accord with the permit issued by the State wide health planning organization and the Agency in mak- Board or whether construction or modification has been ing its determinations; commenced without a permit having been obtained. The (11) Prescribe, with prior approval of the State Board in State Board may issue subpoenas duces tecum requiring consultation with the recognized areawide health planning the production of records and may administer oaths to organizations, rules, regulations, standards and criteria for such witnesses. the conduct of an expeditious review of applications for Any circuit court of this State, upon the application of permits for projects of construction or modification of a the State Board or upon the application of any party to health care facility, which projects are non-substantive in such proceedings, may, in its discretion, compel the at- nature. Such rules shall not abridge the right of areawide tendance of witnesses, the production of books, papers, health planning organizations to make recommendations records, or memoranda and the giving of testimony before on the classification and approval of projects, nor shall the State Board, by a proceeding as for contempt, or such rules prevent the conduct of a public hearing upon otherwise, in the same manner as production of evidence the timely request of an interested party. Such reviews may be compelled before the court. shall not exceed 60 days from the date the application The Agency shall require all health facilities operating is declared to be complete by the Agency; in this State to provide such reasonable reports at such times and containing such information as is needed by it App. 190 App. 191 to carry out the purposes and provisions of this Act. represent the Agency in the proceedings, maintain an ac- Health facilities not complying with this requirement shall tion in the name of the State for injunction or other proc- be reported to licensing, accrediting, certifying, or pay- ess against any person or governmental unit to restrain ment agencies as being in violation of State law. Health or prevent the acquisition of major medical equipment, care facilities and other parties at interest shall have the establishment, construction or modification of a health reasonable access, under rules established by the State care facility without the required permit, or to restrain Board, to all planning information submitted in accord or prevent the occupancy or utilization of the equipment with this Act pertaining to their area. acquired or facility which was constructed or modified Amended by P.A. 80-941, § 1, eff. Sept. 22, 1977. without the required permit. Amended by P.A. 82-745, § 1, eff. May 7, 1982. 1163.1. Necessity of permit § 13.1. Any person constructing or modifying a health 1165.1. Individual liability for damages care facility or portion thereof without obtaining a re- § 15.1. No individual who, as a member of the State quired permit shall not be eligible to apply for any neces- Board or of an areawide health planning organization sary operating licenses or be eligible for payment by any board, or as an employee of the State or of an areawide State agency for services rendered in that facility or por- health planning organization, shall, by reason of his per- tion thereof until the required permit is obtained. formance of any duty, function, or activity required of, Added by P.A. 80-941, § 1, eff. Sept. 22, 1977. or authorized to be undertaken by this Act, be liable for the payment of damages under any law of the State, if 1164. Violations-Fine he has acted within the scope of such duty, function, or activity, has exercised due care, and has acted, with § 14. Any person acquiring major medical equipment respect to that performance, without malice toward any or establishing, constructing or modifying a health care person affected by it. facility without a permit issued under this Act or in viola- tion of the terms of such a permit is guilty of a business Added by P.A. 80-941, § 1, eff. Sept. 22, 1977. offense and may be fined up to $10,000. The State's Attor- neys of the several counties or the Attorney General shall 1166. Partial invalidity represent the People of the State of Illinois in proceedings § 16. If any provision of this Act or the application under this Section. thereof to any person or circumstance shall be held in- Amended by P.A. 82-745, § 1, eff. May 7, 1982. valid, such invalidity shall not affect the provisions or ap- plication of this Act which can be given effect without 1165. Proceedings to prevent acquisition of major medical the invalid provision or application, and to this end the equipment or the establishment, construction or modifi- provisions of the Act are declared to be severable. cation of health care facility $ 15. Notwithstanding the existence or pursuit of any 1167. Home rule unit-Exercise of powers and functions other remedy, the Agency may, in the manner provided § 17. It is hereby specifically declared that the powers by law, upon the advice of the Attorney General who shall and functions exercised and performed by the State pur- suant to this Act are exclusive to the State of Illinois and App. 192 App. 193 that these powers and functions shall not be exercised, APPENDIX K either independently or concurrently, by any home rule unit. Medical Practice Act 1168. Administrative Procedure Act-Application 111 III. Rev. Stat. 1 4400-22 $ 18. The Illinois Administrative Procedure Act, as now or hereafter amended,¹ is hereby expressly adopted and 4400-22. Disciplinary action-Grounds incorporated herein and shall apply to the State Board § 22. A. The Department may revoke, suspend, place and the Agency as if all of the provisions of such Act on probationary status, or take any other disciplinary ac- were included in this Act; except that in case of a con- tion as the Department may deem proper with regard to fliet between the Administrative Procedure Act and this the license or visiting professor permit of any person Act the provisions of this Act shall control. This Section issued under this Act to practice medicine, or to treat applies to the Agency and the State Board 6 months after human ailments without the use of drugs and without op- the effective date of this amendatory Act of 1977. erative surgery upon any of the following grounds: Added by P.A. 80-818, § 1, eff. Sept. 20, 1977. 1. Performance of an elective abortion in any place, I Chapter 127, 1 1001 et seq. locale, facility, or institution other than: (a) a facility licensed pursuant to the "Ambulatory Surgical Treatment Center Act" as heretofore or here- after amended;¹ (b) an institution licensed pursuant to "An Act relating to the inspection, supervision, licensing, and regulation of hospitals" approved July 1, 1953, as heretofore or here- after amended;2 or (c) an ambulatory surgical treatment center or hospital- ization or care facility maintained by the State or any agency thereof, where such department or agency has authority under law to establish and enforce standards for the ambulatory surgical treatment centers, hospitaliza- tion, or care facilities under its management and control; or (d) ambulatory surgical treatment centers, hospitaliza- tion or care facilities maintained by the Federal Govern- ment; or (e) ambulatory surgical treatment centers, hospitaliza- tion or care facilities maintained by any university or col- lege established under the laws of this State and sup- ported principally by public funds raised by taxation; App. 194 App. 195 2. Performance of an abortion procedure in a wilful and 13. Violation of any provision of this Act or of the wanton manner on a woman who was not pregnant at the "Medical Practice Act", approved June 30, 1923, as time the abortion procedure was performed; amended,³ prior to the repeal of that Act, or violation of the rules, or a final administrative action of the Direc- 3. The conviction of a felony in this or any other juris- tor, after consideration of the recommendation of the Dis- diction, except as otherwise provided in subsection B of this Section, whether or not related to practice under this ciplinary Board; Act, or the entry of a guilty or nolo contendere plea to 14. Dividing with anyone other than physicians with a felony charge; whom the licensee practices in a partnership, Professional Association or Medical or Professional Corporation any 4. Gross negligence in practice under this Act; fee, commission, rebate or other form of compensation for 5. Engaging in dishonorable, unethical or unprofessional any professional services not actually and personally ren- conduct of a character likely to deceive, defraud or harm dered. Nothing contained in this subsection prohibits per- the public; sons holding valid and current licenses under this Act 6. Obtaining any fee by fraud, deceit, or misrepresenta- from practicing medicine in partnership under a partner- tion; ship agreement or in a corporation authorized by "The Medical Corporation Act", as now or hereafter amended,4 7. Habitual or excessive use or abuse of drugs defined or as an association authorized by "The Professional Asso- in law as controlled substances, of alcohol, or of any other ciation Act" as now or hereafter amended,5 or under "The substances which results in the inability to practice with Professional Corporation Act" as now or hereafter amend- reasonable judgment, skill or safety; ed,6 or from pooling, sharing, dividing or apportioning the 8. Practicing under a false or, except as provided by fees and monies received by them or by the partnership, law, an assumed name; corporation or association in accordance with the partner- 9. Fraud or misrepresentation in applying for, or pro- ship agreement or the policies of the Board of Directors of the corporation or association. Nothing contained in this curing, a license under this Act or in connection with ap- subsection prohibits 2 or more corporations authorized by plying for renewal of a license under this Act; "The Medical Corporation Act", as now or hereafter 10. Making a false or misleading statement regarding amended, from forming a partnership or joint venture of their skill or the efficacy or value of the medicine, treat- such corporations, and providing medical, surgical and ment, or remedy prescribed by them at their direction in scientific research and knowledge by employees of these the treatment of any disease or other condition of the corporations if such employees are licensed under this Act, body or mind; or from pooling, sharing, dividing, or apportioning the fees 11. Allowing another person or organization to use and monies received by the partnership or joint venture their license, procured under this Act, to practice; in accordance with the partnership or joint venture agree- ment. Nothing contained in this subsection shall abrogate 12. Disciplinary action of another state or jurisdiction the right of 2 or more persons, holding valid and current against a license or other authorization to practice as a licenses under this Act, to each receive adequate compen- medical doctor, doctor of osteopathy or doctor of chiro- sation for concurrently rendering professional services to practic, a certified copy of the record of the action taken a patient and divide a fee; provided, the patient has full by the other state or jurisdiction being prima facie evi- knowledge of the division, and, provided, that the division dence thereof; App. 196 App. 197 is made in proportion to the services performed and re- suant to the Abused and Neglected Child Reporting Act, sponsibility assumed by each; approved June 26, 1975, as now or hereafter amended,8 and upon proof by clear and convincing evidence that the 15. A finding by the Medical Disciplinary Board that licensee has caused a child to be an abused child or neg- the registrant after having his or her license placed on lected child as defined in the Abused and Neglected Child probationary status or subjected to conditions or restric- Reporting Act; tions violated the terms of the probation or failed to com- ply with such terms or conditions; 24. Solicitation of professional patronage by any cor- poration, agents or persons, or profiting from those rep- 16. Abandonment of a patient; resenting themselves to be agents of the licensee; 17. Prescribing, selling, administering, distributing, giv- 25. Gross and wilful and continued overcharging for ing or self-administering any drug classified as a controlled professional services, including filing false statements for substance (designated product) or narcotic for other than collection of fees for which services are not rendered, in- medically accepted therapeutic purposes; cluding, but not limited to, filing such false statements 18. Promotion of the sale of drugs, devices, appliances for collection of monies for services not rendered from the or goods provided for a patient in such manner as to ex- medical assistance program of the Department of Public ploit the patient for financial gain of the physician; Aid under the Public Aid Code; 19. Offering, undertaking or agreeing to cure or treat 26. A pattern of practice or other behavior which dem- disease by a secret method, procedure, treatment or med- onstrates incapacity or incompetence to practice under this icine, or the treating, operating or prescribing for any Act; human condition by a method, means or procedure which 27. Mental illness or disability which results in the in- the licensee refuses to divulge upon demand of the De- ability to practice under this Act with reasonable judg- partment; ment, skill or safety; 20. Immoral conduct in the commission of any act 28. Physical illness, including, but not limited to, deteri- related to the licensee's practice; oration through the aging process, or loss of motor skill 21. Wilfully making or filing false records or reports which results in a physician's inability to practice under in his or her practice as a physician, including, but not this Act with reasonable judgment, skill or safety; limited to, false records to support claims against the med- ical assistance program of the Department of Public Aid 29. Cheating on or attempt to subvert the licensing ex- aminations administered under this Act; under the Public Aid Code;⁷ 22. Wilful omission to file or record, or wilfully im- 30. Wilfully or negligently violating the confidentiality between physician and patient except as required by law; peding the filing or recording, or inducing another per- son to omit to file or record, medical reports as required 31. The use of any false, fraudulent, or deceptive state- by law, or wilfully failing to report an instance of sus- ment in any document connected with practice under this pected abuse or neglect as required by law; Act; 23. Being named as a perpetrator in an indicated report 32. Aiding and abetting an individual not licensed un- by the Department of Children and Family Services pur- der this Act in the practice of a profession licensed under this Act; App. 198 App. 199 33. Violating state or federal laws or regulations re- 3 years next after receipt by the Department of a com- lating to controlled substances; plaint alleging the commission of or notice of the convie- tion order for any of the acts described herein. Except 34. Failure to report to the Department any adverse for the grounds numbered (8), (9) and (29), no action shall final action taken against them by another licensing juris- be commenced more than 5 years after the date of the diction (any other state or any territory of the United incident or act alleged to have violated this Section. In States or any foreign state or country), by any peer re- the event of the settlement of any claim or cause of ac- view body, by any health care institution, by any profes- tion in favor of the claimant or the reduction to final judg- sional society or association related to practice under this ment of any civil action in favor of the plaintiff, such Act, by any governmental agency, by any law enforcement claim, cause of action or civil action being grounded on agency, or by any court for acts or conduct similar to acts the allegation that a person licensed under this Act was or conduct which would constitute grounds for action as negligent in providing care, the Department shall have defined in this Section; an additional period of one year from the date of such 35. Failure to report to the Department surrender of settlement or final judgment in which to investigate and a license or authorization to practice as a medical doc- commence formal disciplinary proceedings under Section tor, a doctor of osteopathy or doctor of chiropractic in 36 of this Act,9 except as otherwise provided by law. The another state or jurisdiction, or surrender of membership time during which the holder of the license was outside on any medical staff or in any medical or professional the State of Illinois shall not be included within any period association or society, while under disciplinary investiga- of time limiting the commencement of disciplinary action tion by any of those authorities or bodies, for acts or con- by the Department. duct similar to acts or conduct which would constitute The entry of an order or judgment by any circuit court grounds for action as defined in this Section; establishing that any person holding a license under this 36. Failure to report to the Department any adverse Act is a person in need of mental treatment operates as judgment, settlement, or award arising from a liability a suspension of that license. That person may resume claim related to acts or conduct similar to acts or con- their practice only upon the entry of a Departmental order duct which would constitute grounds for action as defined based upon a finding by the Medical Disciplinary Board in this Section; that they have been determined to be recovered from 37. Failure to transfer copies of medical records as re- mental illness by the court and upon the Disciplinary Board's recommendation that they be permitted to resume quired by law; their practice. 38. Failure to furnish the Department, its investigators or representatives, relevant information, legally requested The Department may refuse to issue or may suspend by the Department after consultation with the Chief Medi- the license of any person who fails to file a return, or cal Coordinator or the Deputy Medical Coordinator; to pay the tax, penalty or interest shown in a filed return, or to pay any final assessment of tax, penalty or interest, All proceedings to suspend, revoke, place on probation- as required by any tax Act administered by the Illinois ary status, or take any other disciplinary action as the Department of Revenue, until such time as the require- Department may deem proper, with regard to a license on ments of any such tax Act are satisfied. any of the foregoing grounds, must be commenced within App. 200 App. 201 The Department, upon the recommendation of the Dis- by the Disciplinary Board, as a condition for continued, ciplinary Board, shall adopt rules which set forth stan- reinstated, or renewed licensure to practice. Any physi- dards to be used in determining: cian, whose license was granted pursuant to Sections 9, 17, or 19 of this Act, 10 or, continued, reinstated, renewed, (a) When a person will be deemed sufficiently rehabili- disciplined or supervised, subject to such terms, conditions tated to warrant the public trust; or restrictions who shall fail to comply with such terms, (b) What constitutes dishonorable, unethical or unpro- conditions or restrictions, or to complete a required pro- fessional conduct of a character likely to deceive, defraud, gram of care, counseling, or treatment, as determined by or harm the public; the Chief Medical Coordinator or Deputy Medical Coordi- (c) What constitutes immoral conduct in the commis- nators, shall be referred to the Director for a determina- tion as to whether the licensee shall have their license sion of any act related to the licensee's practice; and suspended immediately, pending a hearing by the Discipli- (d) What constitutes gross negligence in the practice nary Board. In instances in which the Director immediate- of medicine. ly suspends a license under this Section, a hearing upon However, no such rule shall be admissible into evidence such person's license must be convened by the Discipli- in any civil action except for review of a licensing or other nary Board within 15 days after such suspension and com- disciplinary action under this Act. pleted without appreciable delay. The Disciplinary Board shall have the authority to review the subject physician's In enforcing this Section, the Illinois State Medical Disci- record of treatment and counseling regarding the impair- plinary Board, upon a showing of a possible violation, may ment, to the extent permitted by applicable federal stat- compel any individual licensed to practice under this Act, utes and regulations safeguarding the confidentiality of or who has applied for licensure or certification pursuant medical records. to this Act, to submit to a mental or physical examina- tion, or both, as required by and at the expense of the An individual licensed under this Act, affected under Department. The examining physician or physicians shall this Section, shall be afforded an opportunity to dem- be those specifically designated by the Disciplinary Board. onstrate to the Disciplinary Board that they can resume The individual to be examined may have, at his or her practice in compliance with acceptable and prevailing stan- own expense, another physician of his or her choice pres- dards under the provisions of their license. ent during all aspects of the examination. Failure of any The Department may promulgate rules for the imposi- individual to submit to mental or physical examination, tion of fines in disciplinary cases, not to exceed $5,000 when directed, shall be grounds for suspension of his or for each violation of this Act. Fines may be imposed in her license until such time as the individual submits to conjunction with other forms of disciplinary action, but the examination if the Disciplinary Board finds, after no- shall not be the exclusive disposition of any disciplinary tice and hearing, that the refusal to submit to the exam- action arising out of conduct resulting in death or injury ination was without reasonable cause. If the Disciplinary to a patient. Any funds collected from such fines shall be Board finds a physician unable to practice because of the deposited in the Medical Disciplinary Fund. reasons set forth in this Section, the Disciplinary Board shall require such physician to submit to care, counsel- B. The Department shall revoke the license or visiting ing, or treatment by physicians approved or designated professor permit of any person issued under this Act to practice medicine or to treat human ailments without the App. 202 App. 203 use of drugs and without operative surgery, who has been APPENDIX L convicted a second time of committing any felony under the Illinois Controlled Substances Act,¹¹ as amended, or who has been convicted a second time of committing a 77 Illinois Administrative Code, Class 1 felony under Sections 8A-3 and 8A-6 of The Illi- nois Public Aid Code, as amended. 12 A person whose li- Chapter 1, $ 205, Subchapter b cense or visiting professor permit is revoked under this subsection B of Section 22 of this Act shall be prohibited TITLE 77: PUBLIC HEALTH from practicing medicine or treating human ailments with- CHAPTER 1: DEPARTMENT OF PUBLIC HEALTH out the use of drugs and without operative surgery. SUBCHAPTER b: HOSPITAL AND AMBULATORY Amended by P.A. 85-686, § 2, eff. Sept. 22, 1987. CARE FACILITIES 1 Chapter 111½, 9 157-8.1 et seq. PART 205 AMBULATORY SURGICAL TREATMENT CENTER 2 Chapter 111½, 9 142 et seq. 3 Paragraph 4401 et seq. of this chapter (repealed; see, now, LICENSING REQUIREMENTS 1 4400-1 et seq. of this chapter). 4 Chapter 32, 1 631 et seq. SUBPART A: GENERAL 5 Chapter 106½, 9 101 et seq. Section 6 Chapter 32, 1 415-1 et seq. 205.110 Definitions 7 Chapter 23, 1 1-1 et seq. 205.120 Licensure B Chapter 23, 1 2051 et seq. 9 Paragraph 4400-36 of this chapter. SUBPART B: OWNERSHIP AND MANAGEMENT 10 Paragraph 4400-9, 4400-17 or 4400-19 of this chapter. Section 11 Chapter 56½, 1 1100 et seq. 205.210 Ownership, Control and Management 12 Chapter 23, 11 8A-3 and 8A-6. 205.220 Organizational Plan 205.230 Standards of Professional Work 205.240 Policies and Procedures Manual SUBPART C: PERSONNEL Section 205.310 Personnel Policies 205.320 Presence of Qualified Physician 205.330 Nursing Personnel 205.340 Basic Life Support 205.350 Ambulatory Surgical Treatment Center App. 204 App. 205 SUBPART D: EQUIPMENT, SUPPLIES, AND SUBPART I: BUILDING DESIGN, CONSTRUCTION FACILITY MAINTENANCE STANDARDS, AND PHYSICAL REQUIREMENTS Section Section 205.410 Equipment 205.1310 Plant and Service Requirements 205.420 Sanitary Facility 205.1320 General Considerations 205.1330 New Construction, Additions and Major SUBPART E: GENERAL PATIENT CARE Alterations 205.1340 Minor Alterations and Remodeling Changes Section 205.1350 Administration Department and Public 205.510 Emergency Care Areas 205.520 Preoperative Care 205.1360 Clinical Facilities 205.530 Operative Care 205.1370 Support Service Areas 205.540 Postoperative Care 205.1380 Diagnostic Facilities 205.1390 Other Building Services SUBPART F: RECORDS AND REPORTS 205.1400 Details and Finishes 205.1410 Construction, Including Fire-Resistive Section Requirements 205.610 Clinical Records 205.620 Statistical Data SUBPART J: MECHANICAL SUBPART G: ADDITIONAL REQUIREMENTS Section FOR FACILITIES IN WHICH OBSTETRICAL/ 205.1510 General GYNECOLOGICAL PROCEDURES ARE PERFORMED 205.1520 Thermal and Acoustical Insulation 205.1530 Steam and Hot Water Systems Section 205.1540 Air Conditioning, Heating and Ventilating 205.710 Abortions Systems 205.720 Personnel 205.730 General Patient Care 205.740 Preoperative Requirements SUBPART K: PLUMBING AND OTHER Postoperative Requirements PIPING SYSTEMS 205.750 205.760 Reports Section 205.1610 General SUBPART H: PROCEDURES 205.1620 Plumbing Fixtures FOR INVESTIGATION OF COMPLAINTS 205.1630 Water System 205.1640 Drainage Systems Section 205.1650 Identification 205.810 Complaints 205.820 Acknowledgement of Complaint 205.830 Investigation 205.840 Prompt Investigation 205.850 Methods 205.860 Notification of Results App. 206 App. 207 nurse-anesthetist by the American Association of Nurse SUBPART L: ELECTRICAL Anesthetists. Section "Department" means the Department of Public Health 205.1710 General of the State of Illinois. 205.1720 Switchboards and Power Panels "Licensed Practical Nurse" means a person licensed un- 205.1730 Panelboards der The Illinois Nursing Act (III. Rev. Stat. 1979, ch. 205.1740 Lighting 111, par. 3401 et seq.) to practice practical nursing. 205.1750 Receptacles (Convenience Outlets) "Qualified Anesthesiologist" means a physician who is 205.1760 Grounding licensed to practice medicine in all its branches in the 205.1770 Equipment Installation in Special Areas State of Illinois and who is a Diplomate of the Amer- 205.1780 Emergency Electric Service ican Board of Anesthesiology; or American College of 205.1790 Fire Alarm System Anesthesiology; or who is a Diplomate of the American Osteopathic Board of Anesthesiology; or who is Board TABLE A General Pressure Relationships and Ventilation eligible or possess training and experience equivalent Rates of Ambulatory Surgery Area to such eligibility; or who possess training and experi- ence acceptable to the Department and whose primary AUTHORITY: Implementing and authorized by the Am- practice is anesthesiology. bulatory Surgical Treatment Center Act (III. Rev. Stat. "Qualified Consulting Committee" means a committee 1981, ch. 111½, pars. 157-8.1 et seq.). whose members are qualified Surgeons, Obstetricians, SOURCE: Amended July 18, 1974; emergency amend- Gynecologists, Anesthesiologists or Pathologists or other ment at 3 III. Reg. 10, p. 43, effective February 23, 1979, Consulting Physicians consisting of not less than 3 mem- for a maximum of 150 days; amended at 3 Ill. Reg. 30, p. bers who shall establish the required standards com- 371, effective July 23, 1979; amended at 5 III. Reg. 12756, mensurate with the size, scope, extent and complexity effective November 4, 1981; amended at 6 Ill. Reg. 6220, of service programs and procedures for which the facil- 6225, and 6226, effective May 17, 1982; amended at 6 III. ity is licensed. The consulting committee shall act as Reg. 10974, effective August 30, 1982; amended at 6 III. the credentials committee. Reg. 13337, effective October 20, 1982; amended at 7 III. "Qualified Consulting Surgeon, Obstetrician, Gynecolo- Reg. 7640, effective June 14, 1983; codified at 8 III. Reg. gist, Anesthesiologist, Pathologist, or other Consulting 9367. Physician" means a physician who is licensed in the State of Illinois and who is a Diplomate of an appropri- ate specialty board or who has completed the training SUBPART A: GENERAL and experience required for specialty board certification. Section 205.110 Definitions "Qualified Physician" means an individual who is li- "Ambulatory Surgical Treatment Center." The term am- censed to practice medicine in all branches in the State bulatory surgical treatment center shall have meaning of Illinois. as ascribed in the "Ambulatory Surgical Treatment "Qualified Dentist" means a dentist who is licensed to Center Act" of 1973 as now and hereafter amended. practice under the Dental Practice Act, (III. Rev. Stat. (The Act) (III. Rev. Stat. 1979, ch. 111½, pars. 157-8.1 1979, ch. 111, pars. 2202 et seq.). et seq.). "Qualified Podiatrist" means a podiatrist who is licensed "Certified Registered Nurse Anesthetist" means a reg- to practice under "An Act to regulate the practice of istered professional nurse who has been certified as a App. 208 App. 209 podiatry in the State of Illinois", (Ill. Rev. Stat. 1979, 6) description of services to be provided by the ch. 111, pars. 4901 et seq.). facility including a list of surgical procedures "Registered Professional Nurse" means a registered to be performed. nurse or a registered professional nurse who is regis- 7) list of all personnel including their name, ad- tered under the Illinois Nursing Act (Ill. Rev. Stat. dress, position, qualifications and licensure. 1979, ch. 111, pars. 3401 et seq.), and practices profes- 8) All applications shall be signed by the applicant sional nursing. and the application shall include a verification "Student Nurse" means a person enrolled in a course form acknowledging the application to be true of instruction at an approved school of professional or and complete and certifying that the applicant practical nursing and who is supervised by a nursing has knowledge of and understands the action instructor of the school. required to comply with the Act and licensing (Source: Amended at 3 III. Reg. 30, p. 371, effective July requirements. The form shall be verified by a notary public. The forms shall be accompanied 23, 1979) by a license fee of $500. 9) As a condition of the issuance or renewal of the Section 205.120 Licensure license of any Ambulatory Surgical Treatment a) An application for license shall be made to the De- Center: partment on forms provided by it. This application A) The applicant shall file a statement of owner- shall contain the information required under the Act ship. The applicant shall agree to update and this Part. The application shall be submitted the information required in the statement not less than sixty (60) days prior to the date of of ownership every 6 months from the ini- intended operation. tial date of filing, b) The application shall include but not be limited to B) Each license shall file an attested financial the following information: statement with the Department by July 1, 1) the name(s) and address(es) of person(s) who 1980 and at times thereafter as required, own and/or operate the facility and the name C) Financial statements shall be filed annual- under which they do business. A corporation ly on or before April 1, of each year for shall submit: the previous calendar year, or within three A) a copy of its certificate of incorporation, (3) months after the close of the fiscal B) list of the title, name, and address of each period of the licensee, D) A financial statement shall be filed with of its corporate officers, C) list of the name and address of each of its the Department on forms provided by the shareholders holding more than 5%, of the Department or on annual financial state- ments prepared on forms used by the ap- shares. 2) location of the facility. plicant. At minimum, they shall include de- 3) description of the facility including but not limited tailed balance sheets, statements of income to interviewing, examination, surgical, and re- and statements of expense. covery room facilities. E) Every facility licensed under this Act, and 4) schematic architectural plans. any premises proposed to be conducted as 5) documentation of compliance with all applicable a facility by an applicant for a license shall building, utility and Safety Codes. App. 210 App. 211 be open during its regular business hours e) The facility shall give written notice to the Depart- to an inspection authorized in writing by ment within seven (7) days of any of the following: the Director. No notice need be given to 1) change of administrative staff, any person prior to any inspection, 2) change of medical director, F) Any corporation operating an Ambulatory 3) change of staff physicians, Surgical Treatment Center devoted primar- 4) change of supervising nurse, ily to providing facilities for abortion must 5) addition or deletion of surgical procedures per- have a physician who is licensed to prac- formed, tice medicine in all of its branches and is 6) in the case of a corporation change in any share- actively engaged in the practice of medicine holders equity involving 5% or more interest. at the center, on the Board of Directors (Source: Amended at 6 III. Reg. 6220, effective May 17, as a condition to licensure of the center. 1982) c) Only those facilities, services, programs and proce- dures included in the application shall be licensed. SUBPART B: OWNERSHIP AND MANAGEMENT A new application is required for the following: 1) change in ownership, Section 205.210 Ownership, Control and Management Ownership, control and management shall be disclosed at 2) change in location, 3) remodeling of facility SO as to change the inter- the time of application. The names and addresses of each viewing, examination, surgical or recovery room person with financial interest in the facility shall be sub- mitted to the Department. space or number, 4) addition of services or programs. (Source: Amended at 3 III. Reg. 30, p. 371, effective AGENCY NOTE: The addition of new spe- July 23, 1979) cialty services, for example, podiatry or ob- Section 205.220 Organizational Plan stetrics/gynecology, may require changes in An organizational plan shall be known to the staff and avail- consulting committee, procedures and/or able for public information in the facility. The document staffing. Therefore, the Department finds shall clearly set forth the organization, duties, responsibil- that a new license is needed. ity, accountability and relationships of professional staff d) The license shall be valid for one (1) year, unless and other personnel. All owners, administrators, profes- sooner suspended or revoked, shall be renewable sional staff and ancillary personnel shall act in accordance annually upon approval by the Department and pay- with this document. This document shall be submitted to ment of a license fee of $300. Each license shall be the Department with the initial application and thereafter issued only for the premises and persons named in will be reviewed at regular inspections by the Department. the application and shall not be transferable or as- (Source: Amended at 3 III. Reg. 30, p. 371, effective signable. The licenses shall be posted in a conspicu- July 23, 1979) ous place on the licensed premises. A placard or Section 205.230 Standards of Professional Work registry of all physicians on staff in the facility shall Management and/or the owner of the ambulatory surgical be centrally located and available for inspection to any interested persons. The renewal application treatment center shall maintain proper standards of pro- shall be on forms provided by the Department and fessional work in the licensed facility. shall be submitted to it not less than 30 days prior to the expiration date. App. 212 App. 213 a) A qualified consulting committee shall be appointed 5) The consulting committee shall act as a tissue in writing by the management and/or owner of the committee and shall review at least quarterly ambulatory surgical treatment center and shall es- pathological reports from procedures performed tablish and enforce standards for professional work by each physician on the staff. Evidence of such in the facility and standards of competency for physi- review shall be recorded in the minutes. cians. The consulting committee shall meet not less b) A qualified physician shall be designated "Medical than quarterly and shall document all meetings with Director." written minutes. These written minutes shall be 1) The Medical Director shall secure compliance maintained at the facility and shall be available for with the policies and procedures pertaining to inspection by the Department. medical and surgical procedures, approved by 1) The membership of the consulting committee the consulting committee. shall reflect the types of procedures performed. 2) The Medical Director shall medically supervise If the facility performs more than 50 procedures the professional personnel involved directly in per month or more than 10% of the total proce- the care of patients undergoing surgical pro- dures performed are in a specific speciality area cedures, including their preoperative and post- then there shall be a consulting physician of operative care and follow-up. that specialty on the consulting committee. 3) The Medical Director shall establish and secure 2) The consulting committee shall review develop- compliance of standards for the observation of ment and content of the written policies and patients by nursing personnel during the post- procedures of the center, the procedures for operative period. granting privileges, and the quality of the sur- (Source: Amended at 3 III. Reg. 30, P. 371, effective gical procedures performed. Evidence of such July 23, 1979) review shall be recorded in the minutes. Section 205.240 Policies and Procedures Manual 3) Credentials shall be provided by those physicians The management/owner of the ambulatory surgical treat- seeking practice privileges. These credentials ment center shall formulate a written policies and proce- shall be reviewed by the credentials committee dures manual. This shall be done in cooperation with the and specific practice privileges identified and medical and professional staff and shall be approved by recorded. Record of such accepted practice privi- the consulting committee. These procedures shall provide leges shall be available for facility staff use and for the acceptance, care, treatment, anesthesia services, public information within the facility. discharge, referral, and follow-up of all patients and all 4) A physician granted specific practice privileges incidental operations of the facility. This manual shall be all provide evidence that he/she has equiva- available to all staff in the center and shall be followed lent practice privileges in at least one licensed by them at all times in the performance of their duties. Illinois hospital. Documentation of said evidence (Source: Amended at 3 III. Reg. 30, p. 371, effective shall be available for inspection by the Depart- July 23, 1979) ment. A list of such privileges granted each physician on the staff of the ambulatory surgi- cal treatment center shall be posted at all times for the staff of the center. App. 214 App. 215 SUBPART C: PERSONNEL Section 205.350 Ambulatory Surgical Treatment Center Section 205.310 Personnel Policies Each ambulatory surgical treatment center shall have one Each ambulatory surgical treatment center shall have of the following: written personnel policies including job descriptions for a) a qualified medical technician who is certified by each staff position, which shall include minimum qualifica- the American Society of Clinical Pathologists or is tions required for the position. There shall be a docu- the holder of a letter, certificate, or record from mented procedure for orientation of new employees to the the Bureau of Quality Assurance of the Department facility's policies and procedures as well as the person- of Health, Education, and Welfare that he/she has nel policies including a copy of the appropriate job descrip- passed the Federal Proficiency Examination Pro- tion. gram for Clinical Laboratory Technologists, to per- (Source: Amended at 3 III. Reg. 30, p. 371, effective form required laboratory procedures. July 23, 1979) b) A written agreement with a laboratory, licensed by Section 205.320 Presence of Qualified Physician the Department, to perform required laboratory A qualified physician shall be present at the facility at procedures. all times during the operative and postoperative period (Source: Amended at 3 III. Reg. 30, p. 371, effective for all patients. July 23, 1979) (Source: Amended at 3 III. Reg. 30, p. 371, effective July 23, 1979) SUBPART D: EQUIPMENT, SUPPLIES, Section 205.330 Nursing Personnel AND FACILITY MAINTENANCE At least one registered professional nurse with postgradu- Section 205.410 Equipment ate education or experience in surgical nursing shall direct Equipment shall be in good working order and shall be and supervise the nursing personnel and the nursing care available in numbers sufficient to provide good patient care of patients and shall be on duty at all times on the prem- based on the procedures to be performed in the facility. ises when patients are present. a) There shall be monitoring equipment, suction ap- Nursing care may be provided by student nurses and paratus, oxygen and related items available within licensed practical nurses who have been trained in the surgical and postoperative recovery area. Car- observation and emergency techniques for preoper- diac pulmonary resuscitation equipment shall be ative and postoperative care of surgical patients and available in all facilities. who are under the direct personnel supervision of a b) There shall be written procedures governing the registered nurse at all times. care, use, sterilization, storage and disposal of all (Source: Amended at 3 III. Reg. 30, p. 371, effective materials to insure that an adequate supply of July 23, (1979) sterile equipment is available for each procedure. The section on "Sterilization and Disinfection" from Section 205.340 Basic Life Support At least one person who is certified in "Basic Life Sup- Infection Control in the Hospital, most recent edi- port" by the American Heart Association shall be on the tion, American Hospital Association, shall be used premises while patients are present. as the guideline. (Source: Amended at 3 III. Reg. 30, p. 371, effective e) There shall be written procedures to assure safety in storage and use of inhalation anesthetics and July 23, 1979) medical gases. The current edition of the National App. 216 App. 217 Fire Protection Association Code (Standard No. 56a) globin or hematocrit and examination of the urine shall be used as the standard. for sugar, protein, and acetone shall be performed d) There shall be written procedures to assure the by a qualified laboratory technician prior to the fol- safety in storage and use of all narcotics and medi- lowing procedures: cations in accordance with state and federal law. 1) those performed with general anesthesia, (Source: Amended at 3 III. Reg. 30, p. 371, effective 2) those performed with local anesthesia with se- July 23, 1979) dation, Section 205.420 Sanitary Facility 3) those performed to terminate pregnancy. The ambulatory surgical treatment center shall insure c) A written statement indicating informed consent maintenance of a sanitary facility with all equipment in and a signed authorization by the patient for the good working order. Written procedures shall include pro- performance of the specific surgical procedure shall vision for garbage and refuse removal, insect and rodent be procured and made part of the patient's clinical control, maintenance of water, heat, ventilation and air record. conditioning, and electrical service. d) Surgical procedures shall not be performed on pa- (Source: Amended at 3 III. Reg. 30, p. 371, effective tient's having medical, surgical, or psychiatric con- July 23, 1979) ditions or complications as specified by the consult- ing committee in the facility's written policies. (Source: Amended at 6 III. Reg. 10974, effective August SUBPART E: GENERAL PATIENT CARE 30, 1982) Section 205.510 Emergency Care Section 205.530 Operative Care a) Each facility shall have a written plan of procedure a) Surgical procedures shall be performed only by a to be followed in case of fire, explosion, or non- qualified physician, dentist or podiatrist within the patient medical emergency. This plan shall specify limits of his/her defined specific practice privileges. persons to be notified and actions to be taken and b) A qualified anesthesiologist, a dental anesthesiolo- shall be known by all staff of the facility. gist or a certified registered nurse anesthetist, b) Each facility shall be prepared to manage those medically directed by a licensed physician who ad- emergencies which may be associated with proce- ministers or directs the administration of anesthesia dures performed there. in an Illinois licensed hospital, shall be present for (Source: Amended at 3 III. Reg. 30, p. 371, effective the administration of anesthetics and recovery of July 23, 1979) patients when any general or major regional anes- thetic is used. Section 205.520 Preoperative Care a) Where medical evaluation, examination, and referral e) All tissues removed during surgery shall be exam- are made from a private physician's office, hospital, ined by a consulting pathologist and all x-rays shall or clinic, pertinent records thereof shall be available be read by a consulting radiologist who shall pro- and made part of the patient's clinical record at the vide a written report of his/her examination to the time the patient is registered and admitted to the attending physician. A copy of this report shall be ambulatory surgical treatment center. filed in the patient's clinical record within seven (7) b) A complete medical history shall be obtained and days. the physical examination shall be complete. A hemo- (Source: Amended at 6 III. Reg. 13337, effective Oc- tober 20, 1982) App. 218 App. 219 Section 205.540 Postoperative Care 2) Limitations and/or restrictions of activities of a) Patients who have had general anesthesia, local the patient. anesthesia with sedation, or a pregnancy termination 3) Specific telephone number to be used by the shall be observed in the facility for a period of time patient, at anytime, should any complication or sufficient to ensure that no immediate postoperative question arise. complications are present. No patient shall be re- 4) A date for follow-up or return visit after the quired to leave the center in less than one (1) hour performance of the surgical procedure which following the procedures. shall be scheduled within six weeks. b) Patients in whom a complication is known or sus- e) Patients shall be discharged only on the written pected to have occurred during or after the per- signed order of a physician. formance of a surgical procedure, shall be informed (Source: Amended at 3 III. Reg. 30, p. 371, effective of such condition and arrangements made for treat- July 23, 1979) ment of the complication. In the event of admis- sion to an inpatient facility a summary of care given SUBPART F: RECORDS AND REPORTS in the ambulatory surgical treatment center con- cerning the suspected complication shall accompany Section 205.610 Clinical Records Accurate and complete clinical records shall be maintained the patient. c) To insure availability of follow-up care at a licensed for each patient and all entries in the clinical record shall hospital, the ambulatory surgical treatment center be made at the time the surgical procedure is performed shall provide written documentation of one of the and when care, treatment, medications, or other medical services are given. The record shall include, but not be following: 1) A transfer agreement with a licensed hospital limited to, the following: within approximately fifteen (15) minutes travel a) patient identification. time of the facility. b) admitting information including patient history, 2) A statement that the medical director of the physical examination findings, diagnosis or need for facility has full admitting privileges at a licensed medical services. hospital within approximately fifteen (15) minutes c) pre-counseling notes. travel time and that he/she will assume respon- d) signed informed consent. sibility for all facility patients requiring such e) confirmation of pregnancy (when abortion is per- formed). follow-up care. 3) A statement that each staff physician, dentist, f) signed physician orders. or podiatrist has admitting privileges in a li- g) laboratory test reports, pathologist's report of tissue, censed hospital within fifteen (15) minutes travel and radiologist's report of x-rays. h) anesthesia record. time of the facility. d) Written instructions shall be issued to all patients i) operative record. in accordance with the standards approved by the j) medication and medical treatments. consulting committee of the ambulatory surgical k) recovery room progress notes. treatment center and shall include the following: I) physician and nurses' progress notes. 1) Symptoms of complications associated with pro- m) condition at time of discharge. cedures performed. App. 220 App. 221 n) patient instructions. Section 205.730 General Patient Care o) post-counseling notes. a) Examination (Source: Amended at 3 III. Reg. 30, p. 371, effective 1) Prior to obstetrical procedures blood Rh factor July 23, 1979) shall be determined by a qualified laboratory Section 205.620 Statistical Data technician for every patient. Each ambulatory surgical treatment center shall submit 2) The physician performing an abortion procedure to the Department annually, clinical statistical data includ- shall establish the diagnosis of pregnancy by ap- ing the following: propriate clinical evaluation and testing prior a) the number and type of procedures performed. to performing an abortion procedure. b) the number and type of complications reported. 3) Time shall be allowed between the initial exam- c) the number of patients requiring transfer to a li- ination and termination of pregnancy to permit censed hospital for treatment of complications. the reporting to and reviewing of all laboratory d) the number of patients returning for follow-up con- tests with the patient by the facility physician. tact. b) Counseling e) the number of deaths. 1) Counseling shall be provided following disclo- (Source: Amended at 3 III. Reg. 30, p. 371, effective sure to the patient of the diagnosis of preg- July 23, 1979) nancy, and prior to performance of any surgical procedure. It shall be done individually and in SUBPART G: ADDITIONAL REQUIREMENTS a room designated for such use which shall not be the procedure room. FOR FACILITIES IN WHICH OBSTETRICAL/GYNECOLOGICAL PROCEDURES 2) All facilities shall provide orientation training for counselors and insure that each counselor ARE PERFORMED is qualified to: Section 205.710 Abortions A) Counseling shall be done by a person quali- Abortions shall be provided to the public with the same fied to: standards of safety, effectiveness, and regard for patients i) discuss alternatives for dealing with rights as any other health service. an unwanted pregnancy; (Source: Amended at 3 Ill. Reg. 30, p. 371, effective ii) describe the procedures used in the July 23, 1979) facility; Section 205.720 Personnel iii) explain the risks and possible compli- At least one registered professional nurse with postgrad- cations of each procedure; uate education or experience in obstetrical or gynecologi- iv) provide contraception information. cal nursing shall supervise and direct the nursing person- B) Demonstration of such counseling qualifica- nel and care of patients having obstetrical procedures. tions shall be required by the Department. AGENCY NOTE: Procedures involving the C) Documentation of orientation training shall pregnant uterus are subject to particular be required by the Department. complications and postoperative care re- D) Counselors shall have no financial interest quires a special knowledge on the part of in the patient's decision. nursing staff. 3) Counseling shall include a discussion of alter- (Source: Amended at 3 III. Reg. 30, p. 371, effective natives, description of the procedure to be per- July 23, 1979) App. 222 App. 223 formed, explanation of risks and possible compli- consent, family planning services may be initiated cations. Contraceptive information may be pro- prior to the discharge of the patient. vided postoperatively. Group counseling may be (Source: Amended at 5 III. Reg. 12756, effective No- provided in addition to individual counseling. vember 4, 1981) The patient's clinical record shall include docu- Section 205.760 Reports mentation of the counseling received. a) A report of each abortion procedure performed in AGENCY NOTE: In the opinion of the Am- an ambulatory surgical treatment center shall be bulatory Surgical Treatment Center Li- made to the Department on forms provided by it. censing Board, the patient should make a These reports shall be submitted not later than ten decision concerning the procedure in an at- (10) days following the month in which the abor- mosphere free from coercion. Consequent- tion was performed. Reports shall be submitted on ly, the Board believes this is best accom- procedures performed whether or not the patient plished in a room separate and apart from was pregnant. the procedure room. The Board believes b) Reports shall not be filled out in such a manner that it is difficult to reach a truly volun- or at such a time as to avoid accurate reporting tary decision while the patient is undressed of complications. and on the procedure table. c) If the facility becomes aware of a complication fol- (Source: Amended at 5 III. Reg. 12756, effective No- lowing the submission of the original report, then vember 4, 1981) a supplemental report shall be submitted to the De- Section 205.740 Preoperative Requirements partment. Abortions may be performed in an ambulatory surgical (Source: Amended at 3 III. Reg. 30, p. 371, effective treatment center on only those patients with gestation up July 23, 1979) to and including 12 weeks commencing with ovulation rather than computed on the basis of the menstrual cycle, SUBPART H: PROCEDURES as determined by the physician, if the patient's medical FOR INVESTIGATION OF COMPLAINTS condition permits. Abortions shall not be performed in an Section 205.810 Complaints Ambulatory Surgical Treatment center on those patients All complaints against ambulatory surgical treatment cen- whose gestation exceeds 12 weeks. ters shall be reported to the Illinois Department of Public (Source: Amended at 3 Ill. Reg. 30, p. 371, effective Health. Complaints should preferably be in writing and July 23, 1979) contain sufficient facts to facilitate the investigation. Com- Section 205.750 Postoperative Requirements plaints by telephone will be accepted. Complaints will a) Each obstetrical/gynecological service shall provide be required in writing if needed to support legal action Rh factor sensitization prophylaxis to all Rh neg- against applicant. ative patients according to standard medical pro- (Source: Amended at 6 III. Rev. 6220, effective May 17, 1982) b) cedures. Information on availability of family planning ser- Section 205.820 Acknowledgement of Complaint vices shall be provided, when desired by the pa- Upon receipt of each complaint the Department will, with- tient. When, in the physician's opinion, it is in the best interest of the patient and with the patient's App. 224 App. 225 in seven (7) days, acknowledge by letter receipt of the SUBPART I: BUILDING DESIGN, CONSTUCTION STANDARDS, AND PHYSICAL REQUIREMENTS complaint. (Source: Amended at 6 III. Reg. 6220, effective May Section 205.1310 Plant and Service Requirements 17, 1982) All ambulatory surgical treatment centers are required Section 205.830 Investigation to meet the following physical plant and service require- If the complaint contains allegations which, if true, would ments. constitute a prima facie violation of the Ambulatory Sur- a) All proposed facilities shall meet these requirements gical Treatment Center Act or this Part an investigation before licensure will be granted. will be conducted. Whenever the complaint concerns mat- b) All existing facilities that are not in compliance with ters outside the jurisdiction of the Department of Public this Section, and subsequent Sections, shall come Health, or may concern matters which are within the into compliance no later than May 17, 1984. jurisdiction of another agency, the complaint also will be (Source: Amended at 7 III. Reg. 7640, effective June referred to the appropriate agency whenever SO doing 14, 1983) does not violate patient confidentiality. Section 205.1320 General Considerations (Source: Amended at 6 III. Reg. 6220, effective May a) Location 17, 1982) This facility shall be identifiably separate from other Section 205.840 Prompt Investigation facilities and functions. The Department will promptly investigate each complaint b) Narrative Program within thirty (30) days of receipt of the complaint. Com- The sponsor for each project shall provide a nar- plaints which constitute a threat to the public health will rative program of functions for the facility which be investigated within ten (10) days of receipt of the com- contains space requirements, staffing patterns, de- partmental relationships and other basic informa- plaint. (Source: Amended at 6 III. Reg. 6220, effective May tion relating to the fulfillment of the institution's objectives. This may be a general or detailed de- 17, 1982) scription of each function to be performed, space Section 205.850 Methods needed for these functions, hours of operation, num- The Department will utilize the most efficient and effec- ber of staff or other occupants of the various spaces, tive methods to investigate each complaint. This may in- types of equipment required, interrelationship of clude inspections pursuant to Section 9 of the Act and various functions and spaces, and description of the issuance of subpoenas and subpoenas duce tecum pur- those services necessary for the complete function- suant to Section 7 of the Act, when appropriate. ing of the facility but which are available elsewhere (Source: Amended at 6 Ill. Reg. 6220, effective May in the community and, therefore, need not be dupli- 17, 1982) cated in this facility. Explain the type of surgery Section 205.860 Notification of Results or procedures, the volume of work, the number of Upon the conclusion of the investigation the complainant doctors, etc. will be notified of the results of the investigation and any c) Size action taken by the Department. The extent (number and types) of the diagnostic, (Source: Amended at 6 III. Reg. 6220, effective May clinical, and administrative facilities to be provided 17, 1982) shall be determined by the services contemplated App. 226 App. 227 and the estimated patient load as described in the 1) The plans shall be drawn at a scale sufficiently large to clearly present the proposed design. narrative program. d) Provisions for the Handicapped 2) The drawings shall include: The design shall provide for accessibility to the phy- A) a plan of each floor including the basement sically handicapped (public, staff, and patients). or ground floor, B) plan showing roads, parking areas, side- e) Privacy for Patient The design of the facility shall provide for the pri- walks, etc., vacy and dignity of the patient during interview, C) elevations of all facades, D) sections through the building, examination, and treatment. (Source: Amended at 6 III. Reg. 6220, effective May E) and all adjacent areas clearly labeled if ad- dition or alteration. 17, 1982) 3) The total gross floor area shall be shown on the Section 205.1330 New Construction, Additions and Major drawings. Alterations 4) Outline specifications shall provide a general de- Requirements and procedures for new construction, addi- scription of the construction including finishes; tions, and major alterations are as follows: acoustical material, its extent and type; heating a) Preliminary drawings and outline specifications and ventilating systems; and the type of elevators. whether for new construction or for substantial al- 5) A brief narrative of the proposed program. terations, shall be submitted to the Department g) Second stage submission. Working Drawings and with a program narrative description for review and Specifications. approval prior to starting final working drawings All working drawings shall be well prepared SO that and specifications. clean and distinct prints may be obtained; be ac- b) The final working drawings and specifications shall curately dimensioned and include all necessary ex- be submitted to the Department for review and ap- planatory notes, schedules and legends. Working proval prior to release of contract documents for drawings shall be complete and adequate for con- bidding. Change orders which affect scope and/or tract purposes. Separate drawings shall be prepared function shall be submitted for approval prior to for each of the following branches of work: Archi- c) The execution. Department shall be notified of the award of tectural, Structural, Mechanical, Electrical. They shall include or contain the following: contracts, and when construction has been com- 1) Architectural Drawings. pleted. Approval by the Department prior to occu- A) Site plan showing all new topography, new- pancy is required. ly established levels and grades, existing d) The preparation and submission of drawings and structures on the site (if any), new build- specifications shall be executed by, or under the im- ings and structures, roadways, walks, and mediate supervision of an architect registered in the the extent of the areas to be landscaped. State of Illinois. All structures and improvements which are e) First stage submission. Design Development Draw- to be removed under the construction con- ings and Outline Specifications. tract shall be shown. f) Development of the preliminary sketch plans indi- B) Plan of each floor. cating in detail the assignment of all spaces, size C) Elevations of each facade. of areas and rooms, indicating in outline, the fixed D) Sections through building. and movable equipment and furniture. App. 228 App. 229 E) If elevators and dumbwaiters are provided, drawings are required showing shaft de- iv) Sizes, types and heating surfaces of tails and dimensions, sizes of cab platforms boilers, furnaces, with stokers and oil and doors, travel distances including eleva- burners, if any. tion height of landings, pit sizes, and ma- v) Pumps, tanks, boiler breeching and piping and boiler room accessories. chine rooms. F) Special care areas, and similar areas shall vi) Air conditioning systems with required be detailed at a scale to show the location, equipment, water and refrigerant pip- ing, and ducts. type, size and connection of all fixed and vii) Supply and exhaust ventilating sys- movable equipment. G) Schedule of finishes. tems with connections and piping. viii) Air quantities for all room supply and 2) Structural Drawings. A) Plans of foundations, floors, roofs and all exhaust ventilating duct openings. intermediate levels shall show a complete B) tems. Plumbing, Drainage and Stand Pipe Sys- design with sizes, sections, and the relative location of the various members. Schedule i) Size and elevation of: street sewer, house sewer, house drains, street of beams, girders and columns. water main and water service into B) Floor levels, column centers, and off-sets the building. shall be dimensioned. C) Special openings and pipe sleeves shall be ii) Location and size of soil, waste, and dimensioned or otherwise noted for easy vent stacks with connections to house drains, cleanouts, fixtures and equip- reference. ment. D) Details of all special connections, assemblies iii) Size and location of hot, cold and cir- and expansion joints shall be given. culating mains, branches, and risers E) Notes on design data shall include the name from the service entrance, and tanks. of the governing building code, values or allowable unit stresses, assumed live loads, iv) Riser diagram of all plumbing stacks with vents, water risers and fixture including wind loads, earthquake load, and connections. soil bearing pressures. 3) Mechanical Drawings. The drawings with specifi- v) Any gas, oxygen and similar piped systems. cations shall show the complete heating, cool- vi) Any standpipe and sprinkler systems. ing and ventilation systems; plumbing, drainage, vii) All fixtures and equipment that re- stand pipe, and sprinkler systems. quire water and drain connections. A) Heating, Cooling and Ventilation. 4) Electrical Drawings. Drawings shall show all i) Any radiators, coils and steam heated electrical wiring, outlets, and equipment which equipment, such as sterilizers. require electrical connections. ii) Heating and steam mains and branches A) Electrical service entrance with switches with pipe sizes. iii) Diagram of heating and steam risers and feeders to the public service feeders, characteristics of the light and power cur- with pipe sizes. rent, transformers and their connections if located in the building. App. 230 App. 231 B) Location of main switchboard, power panels, b) The lobby shall include, if indicated by the approved light panels and equipment. Feeder and program for the facility, the following: conduit sizes shall be shown with schedule 1) wheelchair and cart storage of feeder breakers or switches. 2) reception and information counter C) Light outlets, receptacles, switches, power 3) waiting area outlets, and circuits. 4) public toilets D) Telephone layout showing service entrance, 5) public telephones telephone switchboard, strip boxes, tele- 6) drinking fountain phone outlets and branch conduits as ap- c) Interview spaces for private interviews relating to proved by the telephone company. Where social services, credit, and admissions shall be pro- public telephones are used for inter-com- vided. munication, provide separate room and con- d) Adequate office space for records, business, meet- duits for racks and automatic switching ing, and staff shall be provided. equipment as required by the telephone e) A multipurpose room for conferences, and health company. education purposes including provisions for show- E) Fire alarm system with stations, signal de- ing visual aids shall be provided if required by the vices, control board and wiring diagrams. program. F) Emergency electrical system with outlets, f) Storage spaces shall be provided for: transfer switch, source of supply, feeders, 1) office supplies and circuits as required by the approved 2) sterile supplies, medical/surgical supplies and program as required under the electrical equipment part of these Standards. 3) pharmaceutical supplies (Source: Amended at 6 III. Reg. 6220, effective May 4) housekeeping supplies and equipment 17, 1982) (Source: Amended at 6 III. Reg. 6220, effective May Section 205.1340 Minor Alterations and Remodeling 17, 1982) Changes Section 205.1360 Clinical Facilities Minor alterations and remodeling changes which do not a) Examination room(s) affect the structural integrity of the building, or change 1) Each examination room(s) shall have a minimum functional operation, or which do not affect safety, need clear floor area of 80 square feet, and a mini- not be submitted for prior approval. mum dimension of 8 feet, excluding such spaces (Source: Amended at 6 III. Reg. 6220, effective May as vestibule, toilet, closet, and work counter 17, 1982) (whether fixed or movable). Arrangements shall permit at least 2'-6" clearance at each side and Section 205.1350 Administration Department and Public at both ends of the examination table. Areas 2) A lavatory or sink equipped for handwashing Administration Department and Public Areas are facilities with knee or foot control shall be provided. to be provided when indicated by the approved program. 3) A counter or shelf space for writing shall be a) The entrance shall be sheltered from the weather, provided. located by grade level and must be able to accom- modate wheelchairs and stretchers, if applicable. App. 232 App. 233 b) Procedure room(s) 1) Provide at least one procedure room with a 6) sired. These recovery rooms may be combined, if de- minimum clear area of 250 square feet and a minimum dimension of 14 feet, exclusive of 7) Provide a minimum of four recovery beds fixed and movable cabinets and shelves. Any lounge chairs for each procedure room. At least or other procedure rooms shall not be less than 10 feet. (Source: 17, 1982) Amended at 6 III. Reg. 6220, effective May three may be lounge chairs or beds. one of the four must be a bed, and the other 120 square feet with a minimum dimension of 2) Provide a communication system connecting with the control station. Section 205.1370 Support Service Areas 3) Provide special features such as x-ray film illu- minators, and storage space as required by the a) A control station shall be located to permit program. suite. surveillance of all traffic which enters the operating visual c) Recovery room(s) 1) Room(s) for post-anesthesia recovery for surgi- b) Provide sterilizing facility(ies) with high speed cal patients shall be provided. clave(s) conveniently located to serve all auto- 2) Recovery room(s) shall contain a minimum of for rooms. Approved alternate provisions procedure be 100 square feet of usable floor space for single gery. replacement of sterile instruments may during made sur- bed occupancy and at least 80 square feet per bed for multiple bed occupancy, SO arranged c) A drug distribution station shall be provided that there will be at least 3 feet between beds istered storage to and patients. preparation of medication to be admin- for and 4 feet of clear space at the foot of each bed. d) faucets Scrub stations with knee or foot or elbow 3) This room(s) shall contain a drug distribution shall be provided near the entrances actuated to station, handwashing facility, charting facilities, nurses' station, and storage space for supplies carts. splatter on nearby personnel or arranged supply to procedure minimize rooms. Scrub facilities shall be the and equipment. 4) Provide a toilet which is accessible to the re- e) A soiled workroom for the exclusive use of the covery room, without having to leave the recov- gical suite staff shall be provided. The soiled sur- ery room to reach it. The water closet shall be equipped with a gray diverter valve. tacle. handwashing, waste receptacle, and linen equipped for room shall contain a work counter, sink work- 5) A separate supervised room may be provided sia This room may be used for cleaning anesthe- recep- equipment. for use by patients who are able to leave the f) Fluid waste disposal facilities shall be recovery (post-anesthesia) room but need addi- tional time for all vital signs to be stabilized rooms. ly located with respect to the general convenient- procedure to the point where the patient may leave the g) facility. This room shall be equipped with re- clining or lounge type chairs for patients and 1) A clean workroom or a clean supply room is shall contain a minimum of 50 square feet of usable floor space for each patient to be accom- modated at any one time. workroom shall contain a work counter, sink within the surgical suite prior to use. A clean required when clean materials are assembled equipped for handwashing, and space for clean App. 234 App. 235 and sterile supplies. A clean supply room shall Section 205.1380 Diagnostic Facilities be provided when the narrative program de- If the pre-admission evaluation tests are to be performed fines a system for the storage and distribution within the facility, the following services shall be provided. of clean and sterile supplies which would not a) Radiographic suite, if provided, shall contain the fol- require the use of a clean workroom. lowing: 2) An autoclave shall be incorporated into the 1) film processing area clean workroom. 2) viewing and administration area h) Anesthesia storage facilities shall be provided. 3) film storage facilities Flammable anesthetics are prohibited. 4) toilet room with handwashing facilities, direct- i) Medical gas supply storage with space for reserve ly accessible from each fluoroscopy room with- nitrous oxide and oxygen cylinders shall be pro- out entering the general corridor area. vided, with all tanks properly secured. 5) dressing area with convenient access to toilets. j) Storage area for equipment and supplies used in b) Laboratory suite shall contain the following mini- surgical suite shall be provided. mum facilities: k) Staff and personnel facilities shall be provided for 1) Laboratory work counter with sink and vacuum, male and female personnel (orderlies, technicians, and electric services. nurses, and doctors) working within the surgical 2) Lavatory or counter sink equipped for hand- suite. The areas shall contain lounge, lockers, toilets, washing. lavatories equipped for handwashing, and space for 3) Storage cabinet or closet. changing clothing. These areas shall be arranged to 4) Specimen collection facilities equipped with a provide a one-way traffic pattern SO that person- toilet and lavatory. nel entering from outside the surgical suite can 5) Blood collection facilities shall have space for change, gown, and move directly into the surgical a chair and work counter. suite. Space for removal of scrub suits and foot (Source: Amended at 6 III. Reg. 6220, effective May covers shall be designed SO that personnel using it 17, 1982) will avoid physical contact with clean personnel. Section 205.1390 Other Building Services 1) Provide change areas where patients can change a) Engineering service and equipment areas shall have from street clothing into hospital gowns in privacy, and be prepared for surgery. This shall include sufficient space for equipment rooms for boilers, fur- lockers, toilets, clothing change or gowning area(s), naces, mechanical equipment, and electrical equip- ment. and space for the administration of medications. b) Waste processing services shall be provided for the m) Stretcher storage area shall be out of direct line sanitary storage and disposal of waste by incinera- of traffic. tion, mechanical destruction, compaction, container- n) Janitor's closet containing a floor receptor or ser- ization, removal, or by a combination of these tech- vice sink, and storage space for housekeeping sup- niques. plies and equipment shall be provided exclusively c) Storage rooms for building maintenance supplies for the surgical suite. and yard equipment shall be provided. (Source: Amended at 6 III. Reg. 6220, effective May d) Janitor's closets shall be provided with a floor re- 17, 1982) ceptor or service sink. (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) App. 236 App. 237 Section 205.1400 Details and Finishes j) Thresholds and expansion joint covers shall be made a) Minimum public corridor width shall be 5'-0", ex- flush with the floor surface to facilitate use of cept those corridors where patients are transported wheelchairs and carts. in stretchers or carts shall be 8'-0". k) Air dryers, or paper towel dispensers and waste b) The facility or section shall have at least two exits remote from each other. Other details relating to fixtures. receptacles shall be provided at all handwashing exits and fire safety shall be in accordance with I) Where labeled fire doors are required, these shall Section 13 (Business Occupancy) of the latest edi- be certified by an independent testing laboratory tion of NFPA Standard 101 and the requirements as meeting the construction requirements equal to outlined herein. These Standards govern where dif- those for fire doors in National Fire Protection Asso- ferent from the code. ciation (NFPA) Standard 80. Reference to a labeled c) Items such as drinking fountains, telephone booths, fire door shall be construed to include labeled frame vending machines, and portable equipment shall be and hardware. located SO as not to restrict corridor traffic or reduce m) Radiation protection requirements of X-ray and the corridor width below the required minimum. gamma ray installations shall conform to the re- d) All doors to toilets which may be used by patients quirements of the Department of Nuclear Safety shall be equipped with hardware which will permit Rules for Protection Against Radiation (32 III. Adm. access in any emergency. Code, Subchapter b) and should follow guidelines e) The minimum width of doors for patient access to of NCRP reports #33 dated February 1968, and #49 examination and treatment rooms shall be 3'-0". dated September 1976. Provisions shall be made for f) The minimum width of doors to rooms needing ac- testing and completed installation before use, and cess for stretchers (procedure rooms, recovery) shall all defects must be corrected before use. be 3'-8". n) The minimum ceiling height shall be 8'-0", with the g) Doors on all openings between corridors and rooms following exceptions: or spaces subject to occupancy, except elevator 1) Boiler rooms, if provided, shall have ceiling doors, shall be swing type. clearance not less than 2'-6" above the main h) Doors, except doors to spaces such as small closets boiler header and connecting piping. which are not subject to occupancy, shall not swing 2) Radiographic and other rooms containing ceiling- into corridors in a manner that might obstruct traf- mounted equipment and including those with fic flow or reduce the required corridor width. ceiling-mounted surgical light fixtures shall have i) Doors, sidelights, borrowed lights, and windows in height required to accommodate the equipment which the glazing extends down to within 18 inches and/or fixture. of the floor (thereby creating possibility of acciden- 3) Ceilings in corridors, storage rooms, toilet rooms, tal breakage by pedestrian traffic) shall be glazed and other minor rooms may be not less than with safety glass, wire glass, or plastic glazing ma- 7'-8". terial that will resist breaking and will not create 4) Suspended tracks, rails, and pipes located in dangerous cutting edges when broken in accordance path of normal traffic shall be not less than 6'- with the State of Illinois Safety Glazing Materials 8" above the floor. Act (Ill. Rev. Stat. 1981, ch. 111½, par. 3101 et o) Flammable Anesthetics are prohibited. seq.). Similar materials shall be used in wall open- ings unless required otherwise for fire safety. App. 238 App. 239 p) Cubicle curtains and draperies shall be noncombusti- y) Acoustical ceilings are recommended in corridors, ble or rendered flame retardant and shall pass both multipurpose rooms, and waiting areas. the large and small scale tests of NFPA Standard (Source: Amended at 6 III. Reg. 6220, effective May 701. 17, 1982) q) Interior finish of walls and ceilings of all exit ways, storage rooms, and areas of unusual fire hazard Section 205.1410 Construction, Including Fire-Resistive shall have a flame spread rating of not more than Requirements 25. a) Buildings shall be of the following heights and con- r) Floor finish materials shall have a flame spread struction types with automatic extinguishment sys- rating of not more than 75. If a separate underlay- tem identified in the table below: ment is used with any floor finish material, the flame spread test assembly shall include the under- layment. Construction s) All interior finish materials shall have smoke de- Stories veloped rating of 450 or less. The use of materials Type 1 2 3 Over 3 known to produce large amounts of toxic gases shall be avoided. 2-hour Fire Resistive X X X X t) Floor materials shall be easily cleanable and have 1-hour Protected Noncombustible X X X wear resistance appropriate for the location involved. Noncombustible X X Heavy Timber X X* 1) In all areas frequently subject to wet cleaning 1-hour Protected Ordinary X X* methods, floor materials shall not be physical- 1-hour Protected Wood Frame X* ly affected by germicidal and cleaning solutions. Ordinary X* 2) Floors that are subject to traffic while wet, shall have a nonslip surface. u) Wall finishes shall be washable and in the immedi- Key: ate area of plumbing fixtures, shall be smooth and X = Permitted types of construction. moisture resistant. * = Building requires automatic extinguish- v) Floor and wall penetrations by pipes, ducts, and ment protection except in procedure conduits shall be tightly sealed to minimize entry rooms. Smoke detectors must be installed of rodents and insects. Joints of structural elements in procedure rooms and all rooms not shall be similarly sealed. normally occupied (janitor's closet, stor- w) Ceilings shall be cleanable and those in sensitive age, locker rooms, etc.). areas such as surgical rooms shall be readily wash- b) Walls enclosing stairways, elevator shafts, chutes, able and without crevices that can retain dirt par- and other vertical shafts, boiler rooms, and storage ticles. These sensitive areas shall have a finished rooms (containing combustible materials) shall be of ceiling, covering all overhead ductwork and piping. not less than one-hour fire resistive construction, x) Finished ceilings may be omitted in mechanical and except in buildings over 3 stories in height, where equipment spaces, shops, general storage areas, and 2 hour enclosure is required. similar spaces, unless required for fire-resistive pur- c) Building insulation materials, unless sealed on all poses. sides and edges, shall have a flame spread rating App. 240 App. 241 of 25 or less and a smoke developed rating of 450 5) Chilled water, refrigerant, other process piping or less when tested in accordance with NFPA Stan- and equipment operating with fluid tempera- dard 258. tures below ambient dew point. d) Elevators and Dumbwaiters 6) Water supply and drainage piping with fluid 1) All ambulatory surgical treatment centers lo- temperatures below ambient dew point. cated above the first floor of the building shall 7) Air ducts and casings with outside surface tem- have an electric or electrohydraulic elevator. peratures below ambient dew point. 2) Inspections and tests shall be made, and writ- 8) Other piping, duets, and equipment necessary ten certification be furnished, that the installa- to maintain the efficiency of the system. tion meets the requirements of all applicable b) Insulation may be omitted from hot water and safety regulations and codes. steam condensate piping not subject to contact by (Source: Amended at 6 III. Reg. 6220, effective May patients when such insulation is unnecessary for 17, 1982) preventing excessive system heat loss or excessive heat gain in the surrounding space. SUBPART J: MECHANICAL c) Insulation on cold surfaces shall include an exterior Section 205.1510 General vapor barrier. a) Mechanical systems shall be tested, balanced, and d) Insulation, including finishes and adhesives on ex- operated to demonstrate that the installation and terior surfaces of ducts, pipes, and equipment, shall performance of these systems conform to the require- have a flame spread rating of 25 or less and a smoke ments of these Standards. developed rating of 450 or less as determined by b) Upon completion of the contract, the owner shall an independent testing laboratory in accordance be provided with a complete set of manufacturer's with NFPA 255. Exception: Duct, pipe, and equip- operating, maintenance and preventive maintenance ment coverings shall not be required to meet these instructions, and parts list with numbers and de- requirements where they are located entirely out- scription for each piece of equipment. The owner side the building, or do not penetrate a wall or roof shall also be provided with instruction in the oper- or do not create an exposure hazard. ational use of the systems and equipment as re- e) Linings in air ducts and equipment shall meet the Erosion Test Method described in UL Pub. No. 181. (Source: quired. Amended at 6 III. Reg. 6220, effective May These linings, including coatings and adhesives, and 17, 1982) insulation on exterior surfaces of pipes and ducts Section 205.1520 Thermal and Acoustical Insulation in building spaces used as air supply plenums, shall a) Insulation shall be provided for the following with- have a flame spread rating of 25 or less and a smoke developed rating of 450 or less as determined by in the building: 1) Boilers, smoke breeching and stacks. an independent testing laboratory in accordance 2) Steam supply and condensate return piping. with NFPA 255. 3) Hot water piping above 180° F and all hot f) Duct linings shall not be used in systems supply- ing procedure and recovery rooms unless terminal water heaters. 4) Hot water piping above 125° F which is exposed filters of at least 90 percent efficiency are installed downstream of the linings. to contact by patients. (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) App. 242 App. 243 Section 205.1530 Steam and Hot Water Systems g) The ventilation air supplied to the procedure rooms a) Boilers and/or hot water heaters shall have the shall be delivered at or near the ceiling of the area capacity, based upon the net ratings published by served, and all exhaust or return air from the area the Hydronics Institute, to supply the normal re- shall be removed near the floor level. At least two quirements of all the systems and equipment. exhaust outlets shall be used in each procedure b) Supply and return mains and risers of space heating room. and process steam systems shall be valved to isolate h) All central ventilation or air conditioning systems the various sections of each system. Each piece of shall be equipped with filters having efficiencies not equipment shall be valved at the supply and return less than those specified in the following table: ends. (Source: Amended at 6 III. Reg. 6220, effective May FILTER EFFICIENCIES FOR CENTRAL VENTILATION 17, 1982) AND AIR CONDITIONING SYSTEMS IN Section 205.1540 Air Conditioning, Heating and Ventilat- AMBULATORY SURGICAL TREATMENT FACILITIES ing Systems a) The systems shall be designed to provide the com- Filter fort temperatures and humidities as recommended Efficiencies by ASHRAE Standards. Minimum (Percent) b) Air handling systems shall conform to "Installation Number of Filter Bed Filter Bed of Air Conditioning and Ventilating Systems," NFPA Area Designation Filter Beds No. 1 No. 2 90A-1976. Procedure and c) For spaces not exceeding 25,000 cubic feet in volume, Recovery Rooms 2 25 90 heating, air conditioning, and ventilating systems All Other Areas 1 25 - shall conform to "Standard for the Installation of Warm Air Heating and Air Conditioning Systems, i) All filter efficiencies shall be average atmospheric NFPA 90-B, 1973, except return ducts shall be con- dust spot efficiencies tested in accordance with the structed of materials equal to that specified for sup- American Society of Refrigeration and Heating, Air ply ducts, Chap. 2, paragraph 1.1., Duct Materials. Conditioning Engineers (ASHRAE) Standards 52-68. d) Outdoor air intakes shall be located as far as prac- j) For systems serving procedure and recovery rooms, tical but not less than 15 feet from exhaust outlets filter bed No. 1 shall be located upstream of the of ventilation systems, combustion equipment stacks, conditioning equipment and filter bed No. 2 shall medical-surgical vacuum systems, plumbing vent be located downstream of the supply fan and condi- stacks or from areas which may collect vehicular tioning equipment including humidifiers. exhaust and other noxious fumes. k) Filter frames shall be durable and shall provide an e) All ventilation air outlets and inlets shall conform airtight fit with the enclosing duct work. All joints to NFPA 90A-Chapter 2, paragraph 3.2. Location between filter segments and enclosing duct work of Outlets and Inlets. shall be gasketed or sealed to provide a positive f) The ventilation systems shall be designed and bal- seal against air leakage. anced to provide the ventilation and pressure rela- I) A manometer shall be installed across each filter tionships as shown in Table A. bed serving procedure and recovery rooms. App. 244 App. 245 m) Fire and smoke dampers shall be constructed, lo- c) All fixtures for use by medical and nursing staff cated and installed in accordance with the require- shall be trimmed with valves which can be operated ments of NFPA 90A. without the use of hands. n) All systems, regardless of size, which serve more 1) When blade handles are used for this purpose, than one smoke or fire zone, shall be equipped with the blade handles shall not exceed 4½ inches smoke detectors to shut down fans automatically as in length. specified in paragraph 4-3.1 of NFPA 90A. 2) The serub sinks for surgery shall be trimmed o) The ventilation system for anesthesia storage rooms with valves which are aseptically operated (i.e., shall conform to the requirements of "Standard for knee or foot or elbow actuated) without the use Inhalation Anesthetics" NFPA 56A, including the of hands. Wrist blade handles are not acceptable. gravity option ventilation system. (Source: Amended at 6 III. Reg. 6220, effective May p) Boiler rooms shall be provided with sufficient out- 17, 1982) door air to maintain combustion rates of equipment Section 205.1630 Water System and limit temperatures in working stations to 97° F a) Water systems shall be designed to supply water Effective Temperature as defined by ASHRAE Hand- at sufficient pressure to operate all fixtures and book of Fundamentals. equipment during maximum demand periods. q) Rooms containing heat-producing equipment, such b) Each water service main, branch main, riser, and as boiler rooms and heater rooms, shall be insulated branch to a group of fixtures shall be valved. Stop and ventilated to prevent any floor surface above valves shall be provided at each fixture. from exceeding a temperature of 100° F. c) Approved backflow preventers or vacuum breakers (Source: Amended at 6 III. Reg. 6220, effective May shall be installed on hose bibbs, laboratory sinks, 17, 1982) janitors' sinks, and on all other fixtures to which hoses or tubing are, or can be attached. SUBPART K: PLUMBING AND OTHER d) Water distribution systems shall be arranged to PIPING SYSTEMS provide hot water at each hot water outlet at all Section 205.1610 General times. All plumbing systems shall be designed and installed in (Source: Amended at 6 III. Reg. 6220, effective May accordance with the requirements of the Illinois Plumb- 17, 1982) ing Code (77 III. Adm. Code 890). Section 205.1640 Drainage Systems (Source: Amended at 6 III. Reg. 6220, effective May a) Building sewers shall discharge into a community 17, 1982) sewage system. Section 205.1620 Plumbing Fixtures b) Where a community sewage system is not available, a) Plumbing fixtures shall be of nonabsorptive acid- sewage and liquid wastes shall be collected, treated resistant materials. and disposed of in a private treatment system which must conform to local and State regulations. b) The water supply spout, for lavatories and sinks (Source: Amended at 6 III. Reg. 6220, effective May required for filling pitchers, for medical and nurs- ing staff handwashing, shall be mounted SO that its 17, 1982) discharge point is a minimum perpendicular distance of 5 inches above the rim of the fixture. App. 246 App. 247 Section 205.1650 Identification e) Overload protection devices shall be suitable for All piping for, heating, ventilating and air conditioning, operating properly in the ambient temperature con- and service water systems shall be coded and marked for ditions. easy identification. (Source: Amended at 6 III. Reg. 6220, effective May (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) 17, 1982) Section 205.1730 Panelboards Panelboards serving lighting and appliance circuits shall SUBPART L: ELECTRICAL be located on the same floor as the circuits they serve. Section 205.1710 General This requirement does not apply to any emergency sys- a) All material including equipment, conductors, con- tem circuits. trols, and signaling devices shall be installed to pro- (Source: Amended at 6 III. Reg. 6220, effective May vide a complete electrical system with the necessary 17, 1982) characteristics and capacity to supply the required Section 205.1740 Lighting electrical facilities. All materials shall be listed as a) All spaces occupied by people, machinery, and equip- complying with available standards of Underwriters' ment within buildings, approaches to the buildings, Laboratories, Inc., or other similarly established and parking lots shall have lighting. standards. b) A portable or fixed examination light shall be pro- b) All electrical installations and systems shall be vided in each examination and treatment room. tested to show that the equipment is installed and c) Procedure rooms shall have general lighting, in ad- operates as required. A written record of perform- dition to local lighting provided by adequate light- ance tests on special electrical systems and equip- ing units at the procedure tables. Each lighting unit ment shall be supplied to the owner. Such tests at the tables, except for portable units, shall be con- shall show compliance with the governing codes and nected to an independent circuit. shall include grounding continuity and alarm sys- (Source: Amended at 6 III. Reg. 6220, effective May tems. 17, 1982) (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) Section 205.1750 Receptacles (Convenience Outlets) a) Duplex grounding type receptacles shall be installed Section 205.1720 Switchboards and Power Panels in all areas or rooms in sufficient quantities for the Circuit breakers or fusible switches that provide discon- tasks to be performed. necting means and overcurrent protection for conductors b) A minimum of one duplex receptacle for each wall connected to switchboards and panelboards shall be en- shall be installed in each work area or room, other closed or guarded to provide a dead-front type of as- than storage or locker rooms. sembly. e) A minimum of two duplex receptacles shall be located a) The main switchboard shall be located in a separate .convenient to each examination and work table. enclosure accessible only to authorized persons. d) Duplex receptacles for cleaning equipment and gen- b) The switchboards shall be convenient for use, readi- eral use shall be installed approximately 50'0" apart ly accessible for maintenance, clear of traffic lanes, in all corridors and within 25'0" of ends of corridors. and in a dry ventilated space free of corrosive fumes (Source: Amended at 6 Ill. Reg. 6220, effective May or gases. 17, 1982) App. 248 App. 249 Section 205.1760 Grounding In areas used for patient care or treatment, all receptacles 4) General illumination and selected receptacles in operating at over 100 volts, shall be grounded by an in- the vicinity of the generator set, if installed. sulated copper conductor, sized in accordance with Table 5) Illumination in procedure and recovery room. 250-95 of the 1975 National Electrical Code, and installed 6) If 110 volt equipment will be utilized to main- with the branch conductors supplying these receptacles. tain heart action, breathing, to control bleeding or other essential functions, receptacles con- (Source: Amended at 6 Ill. Reg. 6220, effective May nected to emergency power sources shall be in- 17, 1982) stalled. Standard 205.1770 Equipment Installation in Special Areas (Source: Amended at 6 III. Reg. 6220, effective May a) X-ray Installations. Fixed and mobile X-ray equip- 17, 1982) ment installations, if installed, shall conform to Ar- Section 205.1790 Fire Alarm System ticle 660 of NFPA Standards 70, 1975 Edition. A manually operated electrically supervised fire alarm sys- b) Installation in non-flammable anesthetizing locations tem shall be installed in each facility. of all electrical equipment and devices, receptacles, (Source: Amended at 6 III. Reg. 6220, effective May and wiring shall comply with NFPA Standard 70, 17, 1982) 1975 Edition. Exception: Isolated electrical systems are not required. (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982) Section 205.1780 Emergency Electric Service a) An emergency source of electricity shall be pro- vided and connected to certain circuits for lighting to provide electricity during an interruption of the normal electric supply. b) The source of this emergency electric service shall be a generator set, storage batteries or unit equip- ment as described in Art. 700-6 NFPA Standard 70. c) Emergency electric service shall be provided to the following: 1) Illumination of means of egress as required in NFPA Standard 101. 2) Illumination for exit signs and exit directional signs as required in NFPA Standard 101. 3) Alarm systems including fire alarms activated at manual stations, water flow alarm devices of sprinkler system if electrically operated, fire and smoke detecting systems, and alarms re- quired for nonflammable medical gas systems if installed. App. 250 Section 205. TABLE A General Pressure Relationships and Ven- tilation Rates of Ambulatory Surgery Area Minimum Pressure Total Air All Air Within Relation- Changes per Exhausted Area ship Hour Directly Room Units to Adjacent Supplied to Recircu- Designation Areas to Room Outdoors lated Procedure Room + 15 Optional No Examination Room 0 6 Optional Optional Recovery Room + 6 Optional Optional Medication Area + 4 Optional Optional X-Ray Room 0 6 Optional Optional Soiled Workroom or Soiled Holding - 10 Yes No Clean Workroom or Clean Holding + 4 Optional Optional Darkroom - 10 Yes No Toilet Room - 10 Yes No Janitors' Closet - 10 Yes No Sterilizer Equip. Rm. - 10 Yes No Linen and Trash Rm. - 1- Yes No Laboratory - 6 Optional Optional Soiled Linen Storage - 10 Yes No Clean Linen Storage + 2 Optional Optional Anesthesia Storage 0 8 Yes No Central Services Area Soiled Area - 6 Yes No Clean Area + 4 Optional Optional Equipment Storage 0 2 Optional Optional + = Positive - = Negative 0 = Equal (Source: Amended at 6 III. Reg. 6220, effective May 17, 1982)