In re Lakatos

182 Vt. 487, 2007 Vt. 114
CourtSupreme Court of Vermont
DecidedOctober 19, 2007
Docket2006-014
StatusPublished
Cited by4 cases

This text of 182 Vt. 487 (In re Lakatos) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Lakatos, 182 Vt. 487, 2007 Vt. 114 (Vt. 2007).

Opinion

2007 VT 114

In re Lakatos (2006-014)

2007 VT 114

[Filed 19-Oct-2007]

NOTICE:  This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports.  Readers are requested to notify the Reporter of Decisions, Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801 of any errors in order that corrections may be made before this opinion goes to press.

                                                                   No. 2006-014

In re Peter A. Lakatos, D.M.D.                                                       Supreme Court

                                                                                                         On Appeal from

                                                                                                         Washington Superior Court

February Term, 2007

Helen M. Toor, J.

Kaveh S. Shahi of Cleary Shahi & Aicher, P.C., Rutland, for Petitioner-Appellee.

Robert H. Backus and Hugh L. Brady, Law Clerk, Secretary of State’s Office, Montpelier, for

  Respondent-Appellant.

PRESENT:   Reiber, C.J., Dooley, Johnson and Skoglund, JJ., and Bent, Supr. J.,

Specially Assigned


¶  1.           REIBER, C.J.   The State of Vermont appeals from a superior court order vacating a decision of the Vermont Board of Dental Examiners. Following an evidentiary hearing and disciplinary recommendation by a specially appointed hearing committee, the Board suspended respondent Peter Lakatos, a licensed dentist, for failure to meet minimal standards of practice in numerous instances.  After a summary affirmance by the administrative appellate officer, respondent appealed to the superior court, asserting that (1) the hearing committee utilized by the Board lacked statutory authority, (2) the Board violated his due-process rights by rendering a decision despite the absence of some members from the evidentiary hearing, (3) the evidence was insufficient to support the findings of unprofessional conduct, and (4) the sanctions imposed were arbitrary and capricious.  The court agreed with the procedural and due-process claims, and accordingly vacated the decision and remanded for a new hearing without reaching respondent’s  additional arguments.  On appeal, the State contests the court’s conclusions and contends that respondent waived the claims in any event.  For the reasons set forth below, we reverse and remand.

¶  2.           The material facts may be briefly summarized.[1]  Respondent, an experienced dentist, practiced in Massachusetts for twenty years before moving to Vermont, where he renewed his practice in 1996.  Respondent claims expertise in a number of practice areas, including endodontics, or the treatment of diseases relating to the tooth root and surrounding areas, which comprises about twenty-five percent of his practice.  In October 2001, the Board of Dental Examiners, through the Office of the Attorney General acting as general counsel, filed a specification of charges against respondent containing a number of counts of unprofessional conduct, including one in connection with alleged improper bridge work, four relating to improperly performed root canals or post placements, and one alleging abandonment of a patient.[2] 


¶  3.           Following an exchange of memoranda and motions among the parties and Board counsel relating to the time necessary for presentation of the case and the adequacy of pre-filed testimony, Board counsel sent the parties a letter in April 2002, outlining the procedure which the Board had determined to follow and the dates for the scheduled hearing. Counsel stated that the Board had “decided to proceed under 3 V.S.A. § 811,”[3] explaining that an evidentiary hearing would be held before a  “Board hearing committee” with three members—a dentist, dental hygienist, and  lay person, assisted by a presiding officer—who would then file a proposal for decision with the Board.  The letter indicated that the parties would have an opportunity to discuss the hearing procedure at a previously scheduled prehearing conference in late May unless a more immediate response was required.  Following the prehearing conference, Board counsel issued a memorandum reaffirming the hearing-committee procedure previously outlined and explaining in addition that the parties would have an  “opportunity to file exceptions and present briefs and argument” concerning the proposed decision with the Board, which would consist of the hearing committee plus additional members necessary to reach a quorum of at least five.  It was further agreed that the committee would not make a recommendation on sanctions.


¶  4.           The hearing committee held an evidentiary hearing over the course of four days from July to October 2002.  It issued a report and proposal for decision in December 2002, concluding  that respondent had failed to meet the standards of practice on six of the eight counts alleged.[4]  The report contained numerous findings and conclusions, and respondent filed extensive exceptions and a brief with the Board, which held oral argument in February 2003. Thereafter, in July 2003, the Board—comprising the three hearing-committee members plus six additional members (four dentists, one dental hygienist, and one public member)—issued a lengthy decision containing exhaustive findings and conclusions with citations to the evidentiary record.   Although the Board declined to adopt the committee’s proposed decision, it unanimously concluded—like the committee—that respondent had failed to comport with dental standards of practice on each of the substantive counts alleged, and had therefore committed unprofessional practice under the statutes and regulations governing the practice of dentistry.  Although the parties subsequently reached a stipulation concerning sanctions, the Board rejected the stipulation, heard oral argument, and issued a sanction order suspending respondent from the practice of dentistry for six months, imposing a number of conditions for reinstatement, and requiring a two-year period of supervision by a licensed dentist following reinstatement.  An appellate officer affirmed, and respondent then appealed to the superior court.[5]   3 V.S.A. § 130a. 

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Bluebook (online)
182 Vt. 487, 2007 Vt. 114, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-lakatos-vt-2007.