Educational Commission v. Tulp, O.

CourtSuperior Court of Pennsylvania
DecidedJune 9, 2025
Docket3083 EDA 2023
StatusUnpublished

This text of Educational Commission v. Tulp, O. (Educational Commission v. Tulp, O.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Educational Commission v. Tulp, O., (Pa. Ct. App. 2025).

Opinion

J-A10017-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

EDUCATIONAL COMMISSION FOR : IN THE SUPERIOR COURT OF FOREIGN MEDICAL GRADUATES : PENNSYLVANIA : : v. : : : ORIEN L. TULP, WILLIAM C. REIL, : LAW OFFICES OF WILLIAM C. REIL, : No. 3083 EDA 2023 TOMMY SWATE AND TOMMY SWATE, : ATTORNEY AT LAW : : : APPEAL OF: ORIEN L. TULP :

Appeal from the Judgment Entered on September 18, 2024 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 201001976

BEFORE: PANELLA, P.J.E., BECK, J., and FORD ELLIOTT, P.J.E. *

MEMORANDUM BY BECK, J.: FILED JUNE 9, 2025

Orien L. Tulp (“Dr. Tulp”) appeals from the judgment entered by the

Philadelphia County Court of Common Pleas (“trial court”) in favor of

Educational Commission for Foreign Medical Graduates (“ECFMG”) and Dr.

William Pinsky (collectively, “Plaintiffs”) and against Dr. Tulp, Tommy Swate,

Esquire, and Tommy Swate Attorney at Law. Dr. Tulp challenges the trial

court’s grant of partial summary judgment in favor of Plaintiffs on their claim

of wrongful use of civil proceedings. We affirm.

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A10017-25

ECFMG is a non-profit organization1 that certifies that foreign medical

schools and graduates of those schools have met certain criteria so that the

graduates of those institutions are eligible to pursue post-graduate medical

training, i.e., residencies, in the United States. Dr. Pinsky is the President of

ECFMG. ECFMG’s certification applies only to foreign medical schools and their

students. According to ECFMG criteria, a foreign medical school is an

institution that does not operate within the United States.

Dr. Tulp is the founder and President of the University of Science, Art

and Technology (“USAT”), a private medical school located on the island of

Montserrat, which is a British territory in the Lesser Antilles chain of the West

Indies. In 2018, ECFMG received information indicating that USAT was

offering in-person medical instruction at different locations within the United

States. If such allegations were true, USAT be would in violation ECFMG’s

criteria for accreditation and thus jeopardize its status as a foreign medical

school and its students’ eligibility for residencies in the United States.

1 The Commonwealth Court has exclusive appellate jurisdiction over not-for- profit actions where the application, interpretation or enforcement of a law regulating the corporate affairs of the nonprofit or its members, directors, officers, and the like, and it does not otherwise involve the corporate affairs of the nonprofit, its members, directors, officers, and the like. 42 Pa.C.S. § 762(a)(5). Although ECFMG is a non-profit corporation, this appeal does not fall under the Commonwealth Court’s jurisdiction because ECFMG brought the underlying action for claims of wrongful use of civil proceedings and abuse of process. See id.

-2- J-A10017-25

On August 21, 2018, ECFMG advised Dr. Tulp of the allegations and in

response, he denied them and claimed that USAT was not conducting any

medical instruction within the United States. ECFMG then began an

investigation into USAT. ECFMG sent affidavits to USAT students inquiring

where their medical education and training had taken place. Of the students

that responded, more than 300 indicated that they had taken classes in

different locations within the Unites States and not a single student stated

that they had completed the entirety of their medical education in Montserrat.

On October 18, 2018, ECFMG advised Dr. Tulp that in addition to the

aforementioned allegations, it now had reason to believe he provided ECFMG

with false information in his initial response and invited him to attend its

credential committee meeting in Philadelphia on November 28, 2018. At the

meeting, Dr. Tulp’s attorney, Tommy Swate, Esquire, refused to provide the

committee with any information, accused ECFMG of blackmailing USAT

students, threatened the committee members with personal liability, and

generally refused to cooperate with the committee in any manner or offer any

defense to ECFMG’s allegations. On December 14, 2018, ECFMG informed Dr.

Tulp that it had determined that he had indeed provided ECFMG with false

information and instituted disciplinary actions against Dr. Tulp and USAT.

On December 24, 2018, Dr. Tulp filed suit against Plaintiffs in the United

States District Court for the Eastern District of Pennsylvania in which he raised

claims of, inter alia, tortious interference with a contract, violation of his

-3- J-A10017-25

procedural and substantive due process rights under the Fourteenth

Amendment to the United States Constitution, violation his common law due

process rights, fraud, abuse of process, and negligent misrepresentation.

Attorney Swate and William Reil, Esquire, represented Dr. Tulp in federal

court. Plaintiffs filed a motion to dismiss the complaint and on March 26,

2019, the district court granted the motion as to all claims except the common

law due process claim. See Complaint, 12/3/2020, Exhibit 3 (Tulp v. Educ.

Comm’n for Foreign Med. Graduates, 376 F.Supp.3d 531 (E.D. Pa. Mar.

26, 2019)). Plaintiffs subsequently filed a motion for summary judgment on

the remaining claim, which the district court granted on June 25, 2019. See

id., Exhibit 4 (Tulp v. Educ. Comm’n for Foreign Med. Graduates, 2019

WL 2601066 (E.D. Pa. June 25, 2019)).

Dr. Tulp appealed the district’s court grant of summary judgment on the

common law due process claim to the United States Court of Appeals for the

Third Circuit. In upholding the district court’s grant of summary judgment,

the Third Circuit stated, with respect to the November 2018 credential

committee meeting:

Tulp received notice of the hearing, was allowed to attend with counsel, and was repeatedly invited to offer evidence in his own defense. He deliberately refused to do so. Any resultant loss of an opportunity to be heard rests squarely with Tulp and his counsel, not ECFMG, and Tulp’s argument to the contrary is frivolous.

Id., Exhibit 5 (Tulp v. Educ. Comm’n for Foreign Med. Graduates, 2020

WL 4783646, at *3 (3d Cir. Aug. 17, 2020) (non-precedential decision)).

-4- J-A10017-25

On December 3, 2020, Plaintiffs filed the complaint underlying this

appeal in which they raised claims of wrongful use of civil proceedings and

abuse of process against Dr. Tulip, Attorney Swate and his law firm, Tommy

Swate Attorney at Law, and Attorney Reil and his law firm, the Law Offices of

William C. Reil. On March 1, 2021, the trial court entered default judgment in

favor of Plaintiffs and against Attorney Swate and his law firm for failing to file

an answer. Plaintiffs entered into a settlement agreement with Attorney Reil

and the Law Offices of William C. Reil, and the trial court subsequently

discontinued the case as to those parties. Dr. Tulp proceeded pro se

throughout the early stages of litigation. He did not respond to Plaintiffs’ initial

discovery requests, including their requests for admissions (“RFAs”).

On February 9, 2022, Plaintiffs filed a partial motion for summary

judgment on their claim against Dr. Tulp for wrongful use of civil proceedings.

Plaintiffs later withdrew their abuse of process claim. On March 14, 2022, Dr.

Tulp filed a pro se response.

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