John F. Begg, D.D.S. v. Nicole Alexander-Scott, M.D., in her capacity as Director for the State of Rhode Island Department of Health

CourtSupreme Court of Rhode Island
DecidedDecember 10, 2020
Docket18-155
StatusPublished

This text of John F. Begg, D.D.S. v. Nicole Alexander-Scott, M.D., in her capacity as Director for the State of Rhode Island Department of Health (John F. Begg, D.D.S. v. Nicole Alexander-Scott, M.D., in her capacity as Director for the State of Rhode Island Department of Health) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John F. Begg, D.D.S. v. Nicole Alexander-Scott, M.D., in her capacity as Director for the State of Rhode Island Department of Health, (R.I. 2020).

Opinion

December 10, 2020

Supreme Court

No. 2018-155-M.P. (PC 18-1873)

John F. Begg, D.D.S. :

v. :

Nicole Alexander-Scott, M.D., in her : capacity as Director for the State of Rhode Island Department of Health, et al.

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email: opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Nicole Alexander-Scott, M.D., in her : capacity as Director for the State of Rhode Island Department of Health, et al.

Present: Suttell, C.J., Goldberg, Flaherty, and Robinson, JJ.

OPINION

Justice Goldberg, for the Court. This case came before the Supreme

Court on October 8, 2020, pursuant to a writ of certiorari by the appellant, John F.

Begg, D.D.S., who seeks review of an order and judgment of the Superior Court

denying his administrative appeal from a decision of the Rhode Island Department

of Health (DOH) in favor of the appellees, Nicole Alexander-Scott, M.D., in her

capacity as Director of the DOH (Director); the Board of Examiners in Dentistry of

the DOH (Board); and the DOH. Doctor Begg argues that the trial justice erred:

(1) in finding that DOH was vested with subject-matter jurisdiction to pursue the

underlying administrative proceeding in spite of the fact that DOH failed to

comply with statutory notice provisions; (2) in finding that DOH can compel the -1- production of confidential patient records without a subpoena; and (3) in affirming

DOH’s suspension of the appellant’s license to practice dentistry for two years,

based on his refusal to produce confidential patient information. For the reasons

stated in this opinion, we affirm the judgment of the Superior Court.

Facts and Travel

The appellant has been licensed to practice dentistry in Rhode Island since

January 1, 1969; during the time period relevant to this case, he maintained a place

of business at Lincoln Dental Associates (Lincoln Dental), located in Lincoln,

Rhode Island. On March 21, 2018, appellant filed a Superior Court complaint and

notice of appeal in accordance with the Administrative Procedures Act, G.L. 1956

§ 42-35-15, challenging a decision and order of the Board concerning his dentistry

practice. The complaint alleged that, in January 2016, Dr. Martin Nager performed

an inspection of the records at Lincoln Dental, which led to the issuance of a two-

count specification of charges against Dr. Begg. Count 1 alleged that Dr. Begg

failed to conform to the minimal standards of acceptable practice in maintaining

his patient records, and Count 2 charged Dr. Begg with failure to furnish the Board

with full and complete information as requested by the Board.

A hearing committee of the Board conducted an evidentiary hearing on

July 12 and October 4, 2017, including the presentation of documentary and

testimonial evidence. The Board issued a written decision and order dated

-2- February 7, 2018, which detailed the inspection of Dr. Begg’s patient records and

the shortcomings in those records, including missing documents and required

records. The Board imposed sanctions for violations of G.L. 1956 §§ 5-31.1-

10(19), (23), and (24), and §§ 25.1.1, 27.1(s), 27.1(x), and 27.1(w) of DOH’s then-

existing Rules and Regulations Pertaining to Dentists, Dental Hygienists, and

Dental Assistants. Specifically, as to Count 2, the decision directed that Dr.

Begg’s license to practice dentistry be suspended for two years. As to Count 1—

and before his license could be reinstated after the two-year suspension—Dr. Begg

was required to engage in forty hours of continuing education, including twelve

hours focused on record-keeping, the federal Health Insurance Portability and

Accountability Act of 1996 (HIPAA), and treatment planning records. In addition,

he was required to arrange for an outside monitoring service to review his records

for the first year after his reinstatement and to pay for certain costs and expenses

arising out of the administrative proceedings. The Director adopted the decision

and order of the Board in its entirety on February 13, 2018. Doctor Begg filed a

timely appeal.

Before the Superior Court, Dr. Begg alleged the usual grounds for an

administrative appeal: he argued that the decision was (1) in violation of

constitutional, statutory, or ordinance provisions; (2) in excess of the Board’s and

DOH’s authority; (3) made upon unlawful procedure; (4) affected by other error of

-3- law; (5) clearly erroneous; and (6) arbitrary or capricious or characterized by abuse

of discretion. Doctor Begg presented three arguments in support of his appeal.

First, he asserted that “DOH never had subject matter jurisdiction to pursue the

underlying administrative proceeding because it failed to comply with statutorily

mandated inspection and notice protocols” by failing to leave a copy of the

inspector’s report with Dr. Begg prior to leaving Lincoln Dental. Next, appellant

argued that, even if DOH was vested with subject-matter jurisdiction, its decision

was flawed based on myriad reasons, as set forth in his complaint. Finally, he

maintained that the sanctions imposed were “wholly disproportionate to the

technical records keeping violations” with which he was charged.

The appellees argued that the Board’s decision should be upheld because the

Board was vested with subject-matter jurisdiction in accordance with § 5-31.1-11,

and that there was no statutory support for appellant’s argument that the notice

provision created a “condition precedent for regulatory authority and action.” The

appellees also denied that they were required to seek information from Dr. Begg

only by subpoena or patient consent, and they contended that appellant had

misread § 5-31.1-4(6). Lastly, appellees argued that the sanction imposed was

neither arbitrary, capricious, nor an abuse of power, and that the Board’s decision

was supported by competent evidence and not affected by error of law.

-4- The trial justice entertained argument on April 26, 2018; on May 23, 2018,

she delivered a bench decision denying the appeal and affirming the Board’s

decision. In rendering her decision, the trial justice indicated that she had reviewed

the administrative record, particularly the hearing testimony of Dr. Nager; Linda

Esposito, a DOH employee; Richard Beretta, Esq., Dr. Begg’s prior attorney; and

Mary Begg, Dr. Begg’s office manager.

The trial justice summarized the testimony of Dr. Nager, noting that, after

Dr. Nager’s inspection, appellant provided the documents that Dr. Nager had

reported as missing from the patient files, and that Dr. Nager insisted that those

documents were not in the files when he had inspected them.1 She also referenced

the testimony of Ms. Esposito, who, at the direction of the investigative committee,

requested the complete patient records from the files that Dr. Nager had examined

1 The record before us discloses that Dr. Begg, Ms. Begg, and attorney Beretta were all present at Lincoln Dental during the inspection. Attorney Beretta had pulled ten patient files for Dr. Nager to review, but Dr.

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John F. Begg, D.D.S. v. Nicole Alexander-Scott, M.D., in her capacity as Director for the State of Rhode Island Department of Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-f-begg-dds-v-nicole-alexander-scott-md-in-her-capacity-as-ri-2020.