Conklin v. Oregon Medical Board

CourtDistrict Court, D. Oregon
DecidedSeptember 8, 2025
Docket3:25-cv-01173
StatusUnknown

This text of Conklin v. Oregon Medical Board (Conklin v. Oregon Medical Board) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Conklin v. Oregon Medical Board, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

JEREMY CONKLIN, D.O., an individual, Case No. 3:25-cv-01173-AR

Plaintiff, OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR v. PRELIMINARY INJUCTION

OREGON MEDICAL BOARD, an Oregon State Agency; NICOLE KRISHNASWAMI, an individual; MICHAEL SEIDEL, an individual; and WALTER FRASIER, an individual,

Defendants.

Jeremy Conklin, D.O., 1414 10th Ave., Apt. 734E, Seattle, WA 98112. Pro se.

Marc Abrams, Oregon Department of Justice, 100 SW Market Street, Portland, OR 97201. Attorney for Defendants.

IMMERGUT, District Judge.

PAGE 1 – OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR Before this Court is pro se1 Plaintiff Jeremy Conklin’s Motion for Preliminary Injunction (“Mot.”), ECF 2, under Federal Rule of Civil Procedure 65. Plaintiff alleges that the Oregon Medical Board (“OMB”) discriminates against out-of-state physicians in violation of the Privileges and Immunities Clause and has instituted disciplinary procedures against him in

violation of the Fourteenth Amendment’s Due Process and Equal Protection Clauses. Mot., ECF 2 at 11. Plaintiff asks this Court to issue a preliminary injunction (i) prohibiting OMB from discriminating against out-of-state physicians, (ii) requiring OMB to issue the same medical license to both in-state and out-of-state physicians, (iii) staying OMB’s disciplinary actions against Plaintiff, and (iv) reactivating Plaintiff’s Oregon medical license. Id. at 11–12. On August 27, 2025, this Court held a hearing on Plaintiff’s Motion at which both sides had an opportunity to present additional evidence and argument. Based on the briefing, arguments by Plaintiff and counsel for Defendant, and the current record of the case, this Court DENIES Plaintiff’s Motion for Preliminary Injunction. This Court finds that Plaintiff has not demonstrated that he is likely to succeed on the merits, that he is likely to suffer irreparable harm

in the absence of preliminary relief, or that the balance of equities and public interest tip in favor of issuing the injunction. Even though this finding is based in part on Plaintiff’s likelihood of success on the merits, this Court is not making a final determination about the underlying merits of any of Plaintiff’s claims.

1 Although Plaintiff appears pro se in this matter, he is an attorney admitted to the Washington State Bar. Reply, Ex. II, ECF 16 at 34.

PAGE 2 – OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR BACKGROUND Plaintiff Jeremy Conklin (“Plaintiff”) is an osteopathic physician and Washington resident who held an Oregon locum tenens medical license from 2018 to 2024.2 Complaint (“Compl.”), ECF 1 ¶¶ 15, 21, 23. Defendants are the Oregon Medical Board, its executive director Nicole Krishnaswami, and its investigators Michael Seidel and Walter Frasier.

Id. ¶¶ 3–5. This action arises from Oregon’s regulations for out-of-state medical licensing and OMB’s disciplinary investigation and proceedings against Plaintiff. Plaintiff applied for an Oregon medical license in July 2018. Id. ¶ 8. Plaintiff was told that he cannot qualify for an active Oregon medical license because he does not live or practice within 100 miles of the Oregon border.3 Id. ¶ 10 (emphasis omitted). Plaintiff did, however, qualify for a locum tenens Oregon medical license, and OMB issued him one in October 2018. Id. ¶ 15. The locum tenens license allowed Plaintiff to practice medicine in Oregon for up to 240 days in a two-year period and required him to notify OMB in advance of the location and duration of each of his assignments in Oregon. Id., Ex. AA, ECF 1-2 at 1 (OAR 847-008-0020). In 2019, Plaintiff asked OMB why he could not qualify for an active Oregon medical license. Id.,

Ex. EE, ECF 1-2 at 23. OMB informed Plaintiff that physicians “who actively practice in

2 Locum tenens licenses are issued to “[a]ny licensee whose official state of residence is a state other than Oregon who proposes to practice intermittently within the State.” OAR 847-008-0020. A locum tenens licensee may practice for no more than 240 days within a two-year period and is required to notify OMB of “the location and duration of each Oregon practice prior to [the] beginning of such practice” Id. A locum tenens licensee who does not practice in Oregon during the two-year period “shall be registered as inactive at the time of registration renewal, and shall be required to reactivate to locum tenens registration status prior to practicing in Oregon.” Id. 3 Active medical licenses are issued to licensees “practic[ing] within the State of Oregon” or whose “practice address of record with the Board is within 100 miles of the border of the State of Oregon and who intend[] to practice within Oregon.” OAR 847-008-0015.

PAGE 3 – OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR Oregon, with a current Oregon practice address may register the active license at Active status. Physicians who do not live in Oregon, but who practice intermittently . . . may register the active license at Locum Tenens status, per Oregon Administrative Rule (OAR).” Id. at 22. Plaintiff maintained a locum tenens Oregon medical license through January 2024. Id., Ex. GG, ECF 1-2

at 29. The night of June 5 to June 6, 2023, Plaintiff saw five patients while working at Salem Hospital in Oregon. Id. ¶ 25. A month later, OMB notified Plaintiff that it received a complaint about his conduct at Salem Hospital during the June 5 to June 6, 2023 time period, and opened an investigation based on allegations of medically incompetent care and unprofessional and dishonorable conduct. Id., Ex. JJ, ECF 1-2 at 43. On July 16, 2023, Plaintiff replied to OMB requesting additional detail about the allegations against him so that he could mount his defense. Id., Ex. KK, ECF 1-2 at 49. After OMB provided specific allegations, Plaintiff submitted a detailed summary of his actions on December 6, 2024. Compl., ECF 1 ¶ 47. Apart from OMB’s disciplinary investigation into Plaintiff, on January 31, 2024, OMB

notified Plaintiff that his locum tenens license status would change to inactive if he did not report any employment assignments in Oregon in the last two years. Id., Ex. FF, ECF 1-2 at 26. OMB regulations mandate inactivating a locum tenens license if the licensee does not practice in Oregon within the past two years. Id., Ex. AA, ECF 1-2 at 1. Plaintiff did not respond to OMB’s notification. On February 8, 2024, Plaintiff’s locum tenens medical license was changed to inactive status. Id., Ex. GG, ECF 1-2 at 29. On June 7, 2024, OMB ordered Plaintiff to undergo medical competency examinations pursuant to ORS 677.420 as part of the disciplinary investigation involving his conduct at Salem Hospital. Compl., Ex. MM, ECF 1-2 at 100–01. There is no evidence that Plaintiff underwent the

PAGE 4 – OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR ordered medical competency examinations or replied to the order. On September 5, 2024, OMB requested that Plaintiff appear in person for an interview before the Investigative Committee on December 5, 2024, in Portland. Id., Ex. NN, ECF 1-2 at 109. Plaintiff requested a Zoom link for the interview. Id. An OMB investigator responded that there is not a Zoom option and reiterated

the in-person interview date. Id. at 108. Plaintiff did not appear for the requested interview.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Allen v. Grand Central Aircraft Co.
347 U.S. 535 (Supreme Court, 1954)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Sampson v. Murray
415 U.S. 61 (Supreme Court, 1974)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Supreme Court of NH v. Piper
470 U.S. 274 (Supreme Court, 1985)
Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Kleinsmith v. Shurtleff
571 F.3d 1033 (Tenth Circuit, 2009)
Buckwalter v. Nevada Board of Medical Examiners
678 F.3d 737 (Ninth Circuit, 2012)
McBurney v. Young
133 S. Ct. 1709 (Supreme Court, 2013)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Humenansky v. Minnesota Board of Medical Examiners
525 N.W.2d 559 (Court of Appeals of Minnesota, 1994)
Alexander D. v. State Board of Dental Examiners
231 Cal. App. 3d 92 (California Court of Appeal, 1991)
Schoenefeld v. Schneiderman
821 F.3d 273 (Second Circuit, 2016)
Kevin Marilley v. Charlton Bonham
844 F.3d 841 (Ninth Circuit, 2016)
Clyde Spencer v. Sharon Krause
857 F.3d 789 (Ninth Circuit, 2017)
Fettgather v. Bd. of Psychology
226 Cal. Rptr. 3d 227 (California Court of Appeals, 5th District, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Conklin v. Oregon Medical Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/conklin-v-oregon-medical-board-ord-2025.