Preliminary injunction filed in court by IV Healthcare District against Pioneers district
IMPERIAL VALLEY — A preliminary injunction has been filed in the US District Court by the Imperial Valley Healthcare District (IVHD) against the Pioneers Memorial Healthcare District (PMHD), urging the courts to deny a future ruling in favor of the Pioneers district.
According to a document titled “Opposition of Intervener-Defendant California Attorney General Rob Bonta to Motion for Preliminary Injunction,” as filed on July 26 with the US District Court for the Southern District of California, IVHD lists PMHD’s claims as “lacking standing to maintain” the lawsuit against the IVHD, and “on that basis alone, the motion should be denied.”
The document gives a synopsis of the health care landscape of the Imperial Valley akin to language used in AB
918, noting that “special legislation was needed in Imperial County, in large part, because local officials have tried for years to create a single, countywide healthcare district through the LAFCO process, but without success” and “Pioneers itself did not formally oppose AB 918.”
The preliminary injunction — which is a temporary court order issued early in a lawsuit purported to preserve the status quo and stop harmful actions until the case is decided — “carries the burden of persuasion” on four points, including “establish… likely to succeed on the merits, …likely to suffer irreparable harm in the absence of preliminary relief, “…that the balance of equities tips in favor,” “and that an injunction is in the public interest.”
Per the court document as opined by the IVHD, Pioneers legally fails on all four points.
“Second, Pioneers has failed to meet the requirements for a preliminary injunction,” the court document continues. “Not only has Pioneers failed to show that it is likely to succeed on the merits—which it must do to prevail on this motion—it has not possibility of succeeding on the merits, because all of its claims fail as a matter of law.”
“Pioneers, like other health care districts, is a municipal corporation created by the State. As such, it has not federal constitutional rights against the State…and lacks Article III standing to challenge AB 918 under the Equal Protection Clause (or any other provision of the federal constitution),” it reads within the “Argument” section. “Pioneers fails to carry its burden of establishing a third-party standing.”
Thirdly, “Pioneers also cannot show any irreparable injury, either to itself or to the patients and voters whose rights it purports to champion, but who are in fact being injured by Pioneers’ open defiance of state law,” it reads. “The time and expense occasioned by this baseless litigation are a significant drag on the new district’s ability to get up and running as contemplated by AB 918; Pioneers is actively harming, not helping, the voters and patients it claims to represent.”
“Finally, the balance of hardships and the public interest overwhelmingly weight against the requested injunction,” it reads. “And…the Legislature has considered the public interest and enacted a statue, the public interest weighs strongly against enjoining the law.”
“The Court should deny the motion,” the introduction reads.
“The Legislature expressly found that consolidating county health services under a single umbrella will deliver economies of scale, eliminate duplicative administrative and other functions, and thereby save millions of dollars annually,” the document reads.
“The Legislature further declared that special legislation dissolving Pioneers and Heffernan are transferring their assets to the newly created Imperial Valley was needed to address ‘unique community needs’ in Imperial County,” it reads.
“Pioneers has also not presented any evidence in support of its argument that voters or patients in its district face a ‘genuine obstacle’ to suing on their own behalf,” it reads. “A simple lack of motivation or the lack of a sufficient economic incentive to sue is not enough to support third-party standing. While voters may lack sufficient resources to sue, that does not mean that, as a general matter, voters face special of unique barriers to bringing their own challenge.
“In sum, Pioneers lacks standing, in its own right or otherwise, to bring its federal constitutional challenges to AB 918. On this basis alone, its motion for preliminary injunction should be denied,” the document reads.
Pioneers Memorial Healthcare District media personnel, CEO and board of directors were contacted for a response to the court document, but did not respond by press time on Monday, August 5.