McBride v. Hawkins

CourtDistrict Court, E.D. California
DecidedNovember 19, 2024
Docket2:24-cv-01394
StatusUnknown

This text of McBride v. Hawkins (McBride v. Hawkins) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McBride v. Hawkins, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 Sean McBride, et al., No. 2:24-cv-01394-KJM-AC 12 Plaintiffs, ORDER 13 v. 14 Kristina Lawson, 1S Defendant. 16 17 Plaintiffs Dr. Sean McBride, M.D., and G. Shellye Horowitz have brought this 18 | constitutional challenge against a California law requiring medical doctors obtain California 19 | medical licenses before treating patients in California, even if the treatment is provided over the 20 | phone or in a video call. As explained in this order, plaintiffs’ allegations do not make out 21 | plausible claims, so the complaint is dismissed with leave to amend in part. 22 | I. BACKGROUND 23 Anyone who practices medicine in California without a medical license faces criminal 24 | liability, which could mean as much as a year in prison and a fine of up to $10,000. See Cal. Bus. 25 | & Prof. Code § 2052(a). That is true as well for doctors with licenses from other states. If they 26 | treat patients who are in California at the time of that treatment—“California patients” in this 27 | order—then they must satisfy California’s licensing requirements, which in broad strokes require 28 | proof of postgraduate training, successful completion of a written exam and other background

1 qualifications. See id. §§ 2081, 2135, 2135.5. In addition, applicants must pay a fee, and if they 2 are qualified and receive a license, they must also pay an initial licensing fee and renewal fees 3 every other year. See id. § 2435. Finally, licensed physicians must keep up with continuing 4 medical education requirements set by the state’s medical board. See id. § 2190. 5 These same requirements apply to all types of treatment, whether in person, by phone or 6 over video. See id. § 2290.5(e), (g). Remote or virtual treatment is in fact specifically defined in 7 the state’s laws and regulations as “telehealth” or “telemedicine.” See id. § 2290.5(a)(1), (5), (6). 8 As a result, any doctors who consult with California patients by phone or video are considered to 9 be treating patients in California and must maintain a California license or otherwise risk criminal 10 liability. This is true no matter whether the doctors are themselves in California or another state 11 at the time of treatment. 12 These rules can create problems for patients such as Horowitz. Assuming at this stage the 13 complaint’s allegations are true, Ashcroft v. Iqbal, 556 U.S. 662, 678–79 (2009), Horowitz has 14 been diagnosed with hemophilia A, a rare disorder that affects only a small number of people in 15 the United States, and an even smaller proportion of women. Compl. ¶ 31, ECF No. 1. There are 16 no specialists who can treat her in the small town where she lives. Id. ¶ 35. She attempted to find 17 the care she needed in California for many years, but without success, so she now sees specialists 18 at a hospital in Portland, Oregon. Id. ¶¶ 34–35, 38–40. She still requires regular consultations 19 with her specialists, however, and Portland is more than seven hours from her home by car. See 20 id. ¶¶ 3, 40. It would be much cheaper and more convenient for her to see her doctor by phone or 21 in a video call from her home in California than in person in Oregon. See id. ¶ 3. But as the law 22 currently stands, unless her specialists in Oregon obtain a California license, they would risk 23 criminal liability for treating her under the statutes summarized above. 24 California’s licensing rules can also complicate the medical practices of out-of-state 25 specialists who treat patients in California. Dr. McBride, for example, is an oncologist who 26 works at a specialty cancer hospital in New York and is licensed in New York. Id. ¶ 5. He treats 27 patients from many states, including California. Id. ¶ 6. Sometimes patients must be treated on 28 location in New York, such as those who receive intensive, multi-day radiation treatment, but 1 initial consultations and follow-up visits often can be conducted remotely. See id. ¶¶ 6, 30. For 2 California patients with limited time or means, travel to New York or to another place outside 3 California can be very difficult, even cost-prohibitive, especially when it comes to preparatory 4 visits and initial consultations, which might mean patients settle for less than the best available 5 care. See id. ¶¶ 56–60. Unless doctors like McBride obtain a California license, they must ask all 6 of their California patients to leave California for treatment, which could effectively force out-of- 7 state specialists to choose between accepting fewer California patients or spending time and 8 money to maintain a California license. See id. ¶¶ 48–52. The plaintiffs allege that if specialists 9 are expected to maintain many licenses in many states, it could impose a significant 10 administrative burden. See id. ¶ 45. 11 McBride and Horowitz contend in this case that California’s medical licensing 12 requirements are not only costly and unfair, but also unconstitutional. First, they allege 13 California’s licensing rules violate the constitutional principle that states may not discriminate 14 against out-of-state commerce, explaining that California’s rules effectively impose an extra cost 15 on out-of-state physicians who provide care to California patients. See id. ¶ 63 (citing U.S. 16 Const. art. I, § 8, cl. 3). Second, McBride and Horowitz allege for similar reasons that California 17 has violated the Privileges and Immunities Clause, which guarantees that “Citizens of each state 18 shall be entitled to all Privileges and Immunities of Citizens in the several states.” Id. ¶ 72 19 (quoting U.S. Const. art. IV, § 2, cl. 1). Third, they allege California’s licensing rule 20 unconstitutionally prevents doctors from speaking with patients about their treatment in violation 21 of the First Amendment’s prohibition against laws “abridging the freedom of speech.” See id. 22 ¶¶ 80–93. The complaint names one defendant, the President of the Medical Board of California, 23 in her official capacity. See id. ¶ 12.1 The state Medical Board is the body responsible for 24 licensing and disciplining medical doctors. See id. (citing Cal. Bus. & Prof. Code § 2220). 1 The complaint names Randy Hawkins as the president of the medical board. See id. The court takes judicial notice that Kristina D. Lawson became board president on June 7, 2024. See Fed. R. Evid. 201(b); Medical Board of California, “News Release: Medical Board of California Selects Kristina D. Lawson, J.D. as Board President” (June 7, 2024), 1 The president of the medical board moves to dismiss the complaint for failure to state a 2 claim under Rule 12(b)(6). See generally Mot., ECF No. 10. McBride and Horowitz oppose the 3 motion. See generally Opp’n, ECF No. 11. While briefing was underway, the Goldwater 4 Institute requested permission to file an amicus curiae brief in support of McBride and Horowitz. 5 See Amicus Mot., ECF No. 12; Amicus Br., ECF No. 12-1. The state does not oppose that 6 request, which the court grants. See Cmty. Ass’n for Restoration of Env’t (CARE) v. DeRuyter 7 Bros. Dairy, 54 F. Supp. 2d 974, 975 (E.D. Wash. 1999) (“An amicus brief should normally be 8 allowed . . . when the amicus has unique information or perspective that can help the court 9 beyond the help that the lawyers for the parties are able to provide.”). Briefing is now complete. 10 See generally Reply, ECF No. 13. The court took the matter under submission after a hearing on 11 September 13, 2024. See Mins., ECF No. 16.

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Bluebook (online)
McBride v. Hawkins, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcbride-v-hawkins-caed-2024.