Do No Harm v. Gianforte

CourtDistrict Court, D. Montana
DecidedJanuary 10, 2025
Docket6:24-cv-00024
StatusUnknown

This text of Do No Harm v. Gianforte (Do No Harm v. Gianforte) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Do No Harm v. Gianforte, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA HELENA DIVISION DO NO HARM, CV 24-24-H-BMM-KLD Plaintiff,

vs. FINDINGS & RECOMMENDATION GREGORY GIANFORTE, in his official capacity as Governor of the State of Montana,

Defendant.

Plaintiff Do No Harm brings this action challenging the constitutionality of a Montana statute governing gender and racial balance on appointive boards, commissions, committees, and councils of state government. Defendant Governor Gregory Gianforte (“the Governor”) has filed a Motion to Dismiss the First Amended Complaint for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure. (Doc. 26). For the reasons outlined below, the Governor’s motion should be granted. I. Background The Montana Legislature enacted House Bill 424 during the 1991 Legislative Session. HB 424 is now codified at Mont. Code Ann. § 2-15-108, which provides: Gender and racial balance—report to legislature. (1) As vacancies occur and appointments are made, all appointing authorities of all appointive boards, commissions, committees, and councils of state government shall take positive action to attain gender balance and proportional representation of minorities resident in Montana to the greatest extent possible.

(2) Pursuant to subsection (1), the secretary of state shall publish in the Montana Administrative Register on a monthly basis the recent appointments made by the executive branch and the upcoming vacancies on executive boards and commissions.

(3) The governor shall report to the legislature, as provided in 5-11-210, on the progress made toward achieving the goals set forth in this section.

Mont. Code Ann. § 2-15-108. The Montana Department of Labor and Industry’s Board of Medical Examiners (“the Board”) is one of many state boards that are subject to the gender and racial balance provisions of Mont. Code Ann. § 2-15-108. (Doc. 25 at ¶¶ 1-2). The Board regulates the delivery of healthcare, licenses qualified health professionals, investigates allegations of misconduct, and disciplines health professionals who violate the Board’s rules or regulations. (Doc. 25 at ¶ 21). The Board is comprised of 12 members appointed by the Governor, five of whom must be “doctors of medicine, including one with experience in emergency medicine, none of whom may be from the same county.” (Doc. 25 at ¶ 22; Mont. Code Ann. §2-15-1731(2)(a)). The remaining seven seats must be filled with one doctor of osteopathy; one podiatrist; one nutritionist; one physician assistant; one emergency care provider; and two public members. (Doc. 25 at ¶ 23; Mont. Code Ann. § 2-15- 1731(2)(b)-(g)). Plaintiff Do No Harm is a national non-profit organization whose “mission is focused on keeping divisive identity politics out of healthcare.” (Doc. 25 at ¶7).

Do No Harm’s membership includes more than 6,000 medical professionals, students and policymakers, some of whom are Montana residents. (Doc. 25 at ¶ 7). Do No Harm’s Montana members include four physicians who are not members of

a racial minority group: a female licensed physician, M.D., who practices dermatology in Flathead County (Member A); a male licensed physician, M.D., who practices family medicine in Lake County (Member B); a male licensed physician, M.D., who practices specialty surgery in Gallatin County (Member C);

and a female licensed physician, D.O., who practices family medicine in Lincoln County (Member D). (Doc. 25 at ¶¶ 8-11). Two doctor-of-medicine seats on the Board opened in September 2023.

(Doc. 25 at ¶ 26). Do No Harm filed its Complaint on March 12, 2024, and the two open Board seats were filled three weeks later. (Doc. 25 at ¶ 26). Due to staggered terms, at least one doctor-of-medicine seat on the Board is set to open in September of every year. (Doc. 25 at ¶ 27). The doctor of osteopathy seat on the

Board will open in September 2026. (Doc. 25 at ¶ 28). Openings on the Board can also occur unpredictably in the event of a resignation, removal, or death of a Board member. (Doc. 25 at ¶ 29). Do No Harm filed an Amended Complaint in May

2024, at which time the 12 Board seats were held by eight women and four men. (Doc. 25 at ¶ 31). Do No Harm alleges that Members A, B, C, and D (collectively “the

Members”) are “qualified, ready, willing, and able to be appointed to the Board” for upcoming vacancies, but are disadvantaged by the gender and racial balance provisions of Mont. Code Ann. § 2-15-108. (Doc. 25 at ¶¶ 8-11, 36). Do No Harm

alleges that the “gender and racial mandates” of Mont. Code Ann. § 2-15-108 violate the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution and seeks a declaratory judgment to that effect. (Doc. 25 at ¶¶ 38-49, p. 14). Do No Harm also requests a permanent injunction prohibiting the

Governor from enforcing, or attempting to enforce, the statute’s “gender and racial mandates.” (Doc. 25 at 14). The Governor moves to dismiss the First Amended Complaint for lack of

subject matter jurisdiction on the ground that there is no justiciable case or controversy because Do No Harm lacks constitutional standing, and its claims are not ripe.1 (Doc. 26). II. Legal Standard

Article III of the United States Constitution limits federal court jurisdiction to actual cases and controversies. U.S. Const. art. III, § 2; Allen v. Wright, 468 U.S.

Gianforte filed a similar motion to dismiss Do No Harm’s initial Complaint. 1 (Doc. 19). Because Do No Harm has filed an Amended Complaint, Gianforte’s first motion to dismiss is moot. 737, 750 (1984). Article III’s case or controversy requirement mandates that plaintiffs have standing and that claims be ripe for adjudication. Chandler v. State

Farm Mut. Auto. Ins., 598 F.3d 1115, 1121 (9th Cir. 2010). The irreducible constitutional minimum of standing has three elements: (1) an injury in fact that is concrete and particularized and actual or imminent, not

conjectural or hypothetical; (2) a causal connection between the injury and the conduct complained of; and (3) a likelihood that the injury will be redressed by a favorable decision. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992). The doctrine of ripeness is related to standing and provides federal courts with a

means to “dispose of matters that are premature because the plaintiff’s purported injury is too speculative and may never occur.” Chandler, 598 F.3d at 1122. Because standing and ripeness both relate to a district court’s subject matter

jurisdiction, they are properly raised in a Rule 12(b)(1) motion to dismiss. Chandler, 598 F.3d at 1122. The party asserting federal subject matter jurisdiction bears the burden of establishing its existence. Chandler, 598 F.3d at 1122. “A Rule 12(b)(1) jurisdictional attack may be facial or factual.” Safe Air for

Everyone v. Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004). “In a facial attack, the challenger asserts that the allegations contained in a complaint are insufficient on their face to invoke federal jurisdiction. By contrast, in a factual attack, the

challenger disputes the truth of the allegations that, by themselves, would otherwise invoke federal jurisdiction.” Safe Air for Everyone, 373 F.3d at 1039. Here, the Governor’s argument that Do No Harm has not alleged sufficient

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