Jeremy Conklin v. Oregon Medical Board, an Oregon State Agency; Nicole Krishnaswami, an individual; Michael Seidel, an individual; and Walter Frasier, an individual

CourtDistrict Court, D. Oregon
DecidedJune 12, 2026
Docket3:25-cv-01173
StatusUnknown

This text of Jeremy Conklin v. Oregon Medical Board, an Oregon State Agency; Nicole Krishnaswami, an individual; Michael Seidel, an individual; and Walter Frasier, an individual (Jeremy Conklin v. Oregon Medical Board, an Oregon State Agency; Nicole Krishnaswami, an individual; Michael Seidel, an individual; and Walter Frasier, an individual) 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.

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Jeremy Conklin v. Oregon Medical Board, an Oregon State Agency; Nicole Krishnaswami, an individual; Michael Seidel, an individual; and Walter Frasier, an individual, (D. Or. 2026).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

JEREMY CONKLIN, Ca se No. 3:25-cv-01173-AR

Plaintiff, OPINION AND ORDER

v.

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

Defendants. _____________________________________

ARMISTEAD, United States Magistrate Judge

Plaintiff and osteopathic physician Jeremy Conklin, representing himself,1 brings this lawsuit challenging an ongoing disciplinary investigation by the Oregon Medical Board (OMB). In addition to suing OMB, Conklin sues OMB executive director Nicole Krishnaswami, and investigators Michael Seidel and Walter Frasier in (what appears to be) their individual

1 Plaintiff is licensed as an attorney in Washington. (See Compl. at 38, ECF 1 (listing Conklin’s Washington bar number in his signature); Resp. at 28, ECF 24 (same).) capacities. Conklin alleges that OMB’s investigation into his conduct at Salem Hospital and inactivation of his locum tenens license, among other things, denied him due process, violated the Privileges and Immunities Clause, and violated the Equal Protection Clause. And those constitutional violations by the defendants resulted, Conklin alleges, in both intentional and negligent infliction of emotional distress. Defendants move under Federal Rule of Civil Procedure 12(b)(6) to dismiss all claims. For the reasons discussed below, that motion is GRANTED. BACKGROUND Jeremy Conklin is an osteopathic physician who resides in Washington. In July 2018,

Conklin applied for an Oregon medical license to practice at Providence Medford Medical Center in Oregon as a locum tenens physician. Conklin worked with a healthcare staffing agency, CompHealth, to complete his application. Conklin was informed by a CompHealth employee that, per the OMB, he did not qualify for an active Oregon medical license because he did not “live or practice within 100 miles of the Oregon border.” (Compl. ¶¶ 8-10, ECF 1.) He did, however, qualify for a locum tenens license—a temporary license to practice medicine in Oregon for physicians who reside out of state.2 (Id.)

2 See OAR 847-008-0020 (1) (“Any licensee whose official state of residence is a state other than Oregon who proposes to practice intermittently within the State shall register and pay the biennial locum tenens registration fee.”).

Page 2 – OPINION AND ORDER Conklin v. Oregon Medical Board, et al., 3:25-cv-01173-AR Conklin then applied for an Oregon locum tenens license. During the application process, Conklin was notified and fined $195 under OAR 847-008-00583 because of incorrect information on his Oregon license application. (Compl. ¶ 11.) Conklin moved to dismiss that civil penalty, but that motion was allegedly “ignored” by the OMB. (Id. ¶ 13.) Conklin eventually paid the fee and successfully obtained a locum tenens license in October 2018. (Id. ¶ 15.) In October 2020, Conklin received a notice from OMB that his license would be changed to inactive status if he failed to report any locum tenens assignments in Oregon from 2018 to 2019. Conklin asserts that “physicians who are residents of Oregon and have an active Oregon

Medical License” are not required to provide yearly proof of employment. (Id. ¶¶ 16-18.) Before receiving that notice, Conklin asked OMB why he could not obtain an Oregon medical license and thus eliminate the need to report his employment every year. (Id. ¶ 19, Ex. EE, ECF 1-2 at 21.)4 Conklin alleges in his complaint that, in response, OMB told him that “because [he] did not live in Oregon, but intermittently practiced medicine less than 240 days in Oregon every two

3 Under that rule, “omissions or false, misleading, or deceptive statements or information on any [OMB] application, affidavit or registration is a violation of ORS 677.190” and grounds for a fine.

4 Conklin relies upon several exhibits attached to his complaint, the validity of which defendants do not dispute. The court therefore incorporates those exhibits by reference. See Davis v. HSBC Bank Nevada, N.A., 691 F.3d 1152, 1159 (9th Cir. 2012) (“[T]he district court may but is not required to incorporate documents by reference.”); United States v. Ritchie, 342 F.3d 903, 908 (9th Cir.2003) (explaining that a document “may be incorporated by reference into a complaint if the plaintiff refers extensively to the document or the document forms the basis of the plaintiff'’s claim”).

Page 3 – OPINION AND ORDER Conklin v. Oregon Medical Board, et al., 3:25-cv-01173-AR years,” he was only eligible for a locum tenens license and not an Oregon medical license.5 Conklin then reported his 2018-19 employment, and his license was renewed. (Id. ¶¶ 20-21.) OMB again issued a notice to Conklin on January 31, 2024, regarding his failure to timely report any employment in Oregon. (Id. ¶ 22, Ex. FF, ECF 1-2 at 26.) On February 8, 2024, when Conklin did not respond, he was informed by a letter signed by Krishnaswami that his license was changed to inactive status. (Id. ¶ 23, Ex. GG, ECF 1-2 at 29.) Before OMB changed Conklin’s license to inactive status, Conklin took a locum tenens contract with Salem Hospital in Oregon. Conklin was scheduled for a night shift surgery assignment starting on June 5, 2023. During that shift, Conklin saw five patients and tried to

schedule each of them for emergency surgeries that evening. Yet Conklin was told by Salem Hospital staff that there were no available operating rooms or teams to staff operating rooms. (Id. ¶¶ 24-26.) Conklin was able to schedule one of his cases, but Salem Hospital required that another doctor proctor the operation. The proctor and Conklin disagreed about medical procedures, and the proctor asked Conklin to leave before the operation was finished. Conklin alleges that another of his patients died because of a delay of an operation. (Id. ¶¶ 28-29, 31.)

5 OMB’s response, attached to Conklin’s complaint, stated the following: Physicians who actively practice in 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 within Oregon for no more than 240 days every two years may register the active license at Locum Tenens status, per Oregon Administrative Rule (OAR). (Ex. EE, ECF 1-2 at 22.)

Page 4 – OPINION AND ORDER Conklin v. Oregon Medical Board, et al., 3:25-cv-01173-AR The next day, Conklin complained to the Salem Health Medical Director and CEO that the proctor interfered with his treatment of a patient. That same day, Salem Hospital canceled Conklin’s locum tenens assignment. (Id. ¶¶ 32-33.) Conklin received a notice, dated July 5, 2023, from OMB regarding a complaint from Salem Hospital, alleging that Conklin provided medically incompetent care for four patients he treated on the night of June 5 and acted in an unprofessional and dishonorable manner. (Id. ¶¶ 38-39.) On July 16, Conklin asked OMB to provide more details about the allegations, which OMB provided. Conklin responded on December 6, 2023, with a description of his actions. (Id. ¶¶ 16, 47) Meanwhile, Salem Hospital’s peer review committee reviewed Conklin’s treatment of the

four patients and determined in October 2023 that there were no deficiencies in Conklin’s care and that he had not behaved dishonorably or unprofessionally. (Id. ¶¶ 42-43.) OMB continued to pursue its investigation into Conklin’s conduct at Salem Hospital, however. In June 2024, OMB ordered Conklin to undergo two medical competency examinations, one in Kansas and one in Colorado. (Id. ¶ 48, Ex.

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Jeremy Conklin v. Oregon Medical Board, an Oregon State Agency; Nicole Krishnaswami, an individual; Michael Seidel, an individual; and Walter Frasier, an individual, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeremy-conklin-v-oregon-medical-board-an-oregon-state-agency-nicole-ord-2026.