Select Specialty Hospital v. In re Bullard — Appeal dismissed as moot

Case
Select Specialty Hospital, Pensacola, Inc. v. In re Eddie Bullard, an Alleged Incapacitated Person
Court
Florida First District Court of Appeal
Judge
Roberts; Rowe; Kelsey
Date Decided
September 30, 2026
Docket No.
1D2026-0136
Topics
Appellate Procedure; Mootness; Guardianship
Source
Read the full opinion

Background

Select Specialty Hospital, Pensacola, Inc. appealed from a proceeding in the Circuit Court for Escambia County concerning Eddie Bullard, an alleged incapacitated person. Circuit Judge W. Joel Boles presided below.

The First District’s brief per curiam opinion does not describe the underlying dispute, the order under review, or the events that rendered the appeal moot. The Florida Hospital Association and the Florida Defense Lawyers Association participated as amici curiae.

The Court’s Holding

The First District Court of Appeal dismissed the appeal as moot.

The court provided no additional reasoning and did not address the merits of the hospital’s appeal. Judges Roberts, Rowe, and Kelsey concurred.

Key Takeaways

  • The appeal was dismissed on mootness grounds.
  • The court did not decide the merits of the underlying dispute.
  • The opinion does not identify what circumstances made the appeal moot.

Why It Matters

The decision ends this appeal without establishing a substantive rule governing alleged-incapacity proceedings or hospital rights. Because the opinion contains no factual discussion or legal analysis, its significance is limited to the disposition of this case and the application of mootness principles at the appellate stage.

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