Feathers v. West Virginia Board of Medicine

562 S.E.2d 488, 211 W. Va. 96, 2001 W. Va. LEXIS 153
CourtWest Virginia Supreme Court
DecidedNovember 28, 2001
Docket29634
StatusPublished
Cited by11 cases

This text of 562 S.E.2d 488 (Feathers v. West Virginia Board of Medicine) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Feathers v. West Virginia Board of Medicine, 562 S.E.2d 488, 211 W. Va. 96, 2001 W. Va. LEXIS 153 (W. Va. 2001).

Opinion

STARCHER, Justice.

In this appeal from the Circuit Court of Kanawha County, an appellant sought a writ of prohibition from the circuit court to quash an administrative subpoena duces tecum issued by a state agency. The appellant contends that an administrative subpoena cannot be issued without the state agency first making a specific determination that probable cause exists to believe a statute or regulation has been violated. The appellant challenged the subpoena primarily because the agency made no probable cause determination that the appellant had engaged in any wrongdoing.

The circuit court denied the requested writ of prohibition. As set forth below, we affirm the circuit court’s decision.

I.

Facts & Background

Appellant Scott James Feathers is a practicing podiatrist with offices in Parkersburg and Hurricane, West Virginia. Dr. Feathers is subject to regulation by the appellee, the West Virginia Board of Medicine (“Board”). In the instant ease, the Board is investigating whether Dr. Feathers has engaged in misconduct under the West Virginia Medical Practice Act, W.Va.Code, 30-3-1 to -17.

The Board’s regulations, enacted pursuant to the Medical Practice Act, 1 state that it may discipline a physician or podiatrist who *99 has “[e]ngaged in dishonorable, unethical or unprofessional conduct of a character likely to deceive, defraud or harm the public or any member thereof[.]” 11 C.S.R. lA.12.1.e [2001]. The regulations define “dishonorable, unethical or unprofessional conduct” as including “charging or collecting an excessive, unconscionable fee.” 11 C.S.R. 1A.12.2.Í [2001]. 2

A former patient of Dr. Feathers complained to the Board, alleging that Dr. Feathers had charged the patient and her insurance company an excessive fee. The Board investigated the patient’s complaint, and had an informal conference with Dr. Feathers to discuss the patient’s allegations. 3

At that informal conference, Dr. Feathers presented the Board with a March 9, 2000 opinion letter prepared by a podiatrist at Dr. Feathers’ request. The opinion letter stated that the podiatrist had reviewed the former patient’s file to determine if Dr. Feathers had committed “any violation of the Medical Practice Act.” The podiatrist had reviewed the patient’s billing information, and concluded that:

... while Dr. Feathers’ charges are more than the base charges that I see in my office and in my area of the state, these are Dr. Feathers’ published charges and therefore there has not been any violation that I can see from the standpoint of overcharging. ... The total charges do amount to quite a bit of money; however, chronic heel pain can be extremely complicated and I have seen cases which involved much more financial drain on the insurance companies and patients than this particular case.

The Board determined that the podiatrist’s statement that Dr. Feathers’ charges were “more than the base charges that I see in my office and in my area of the state” led the Board to decide that further investigation was needed to determine if Dr. Feathers was charging his patients excessive fees.

On April 4, 2000, the Board issued a subpoena duces tecum to Dr. Feathers, directing that he provide certain documents to the Board. First, the Board requested “[cjopies of any and all written fee schedules and office billing procedure manuals.” The parties agree that Dr. Feathers provided these documents to the Board.

Second, the Board sought “copies of the thirty (30) medical records randomly selected by the Board Investigator.” 4 Dr. Feathers refused to produce these documents. On April 7, 2000, he filed a petition for a writ of prohibition with the circuit court to quash the subpoena duces tecum. Dr. Feathers contended that the Board had no authority to *100 issue the subpoena, because the Board did not make a finding that there was probable cause to believe Dr. Feathers had violated the Medical Practice Act. Furthermore, Dr. Feathers argued that the Board simply wanted to engage in a “fishing expedition” through his files, violating his patients’ right to privacy.

On June 21, 2000, the circuit court entered an order denying the requested writ of prohibition. The circuit court reasoned that the Board did not need probable cause to subpoena records as part of an investigation, and that the Board’s regulations allowed the use of a subpoena to further any investigation by the Board when the subpoena would likely lead to admissible evidence. The circuit court also determined that a review of 30 patient records to determine if there were irregular billing practices would not amount to an unreasonable and oppressive request. Additionally, the circuit court found that the Board itself is charged with protecting a patient’s right to the confidentiality of medical information contained in them medical file, and that a doctor cannot assert a patient’s right to confidentiality to limit a legitimate investigation intended to benefit the public health. The circuit court therefore ordered Dr. Feathers to comply with the subpoena duces tecum.

Dr. Feathers then filed the instant appeal.

II.

Standard of Review

Dr. Feathers seeks a writ of prohibition to halt the enforcement of the Board’s subpoena. “The rationale behind a writ of prohibition is that by issuing certain orders the trial court has exceeded its jurisdiction, thus making prohibition appropriate.” State ex rel Allen v. Bedell, 193 W.Va. 32, 36, 454 S.E.2d 77, 81 (1994) (Cleckley, J., concurring). As such, “writs of prohibition ... provide a drastic remedy to be invoked only in extraordinary situations.” 193 W.Va. at 37, 454 S.E.2d at 82.

There are five factors that a court will consider in determining whether it is appropriate to issue a writ of prohibition:

In determining whether to entertain and issue the writ of prohibition for cases not involving an absence of jurisdiction but only where it is claimed that the lower tribunal exceeded its legitimate powers, this Court will examine five factors: (1) whether the party seeking the writ has no other adequate means, such as direct appeal, to obtain the desued relief; (2) whether the petitioner will be damaged or prejudiced in a way that is not eoiTectable on appeal; (3) whether the lower tribunal’s order is clearly erroneous as a matter of law; (4) whether the lower tribunal’s order is an oft l'epeated eiuor or manifests persistent disregard for either procedural or substantive law; and (5) whether the lower tribunal’s order raises new and important problems or issues of law of first impression. These faetoi's are genei'al guidelines that serve as a useful starting point for determining whether a discretionary writ of pi'ohibition should issue. Although all five factors need not be satisfied, it is clear that the third factor, the existence of clear error as a matter of law, should be given substantial weight.

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Bluebook (online)
562 S.E.2d 488, 211 W. Va. 96, 2001 W. Va. LEXIS 153, Counsel Stack Legal Research, https://law.counselstack.com/opinion/feathers-v-west-virginia-board-of-medicine-wva-2001.