Megdal v. Oregon State Board of Dental Examiners

586 P.2d 816, 37 Or. App. 219, 1978 Ore. App. LEXIS 2128
CourtCourt of Appeals of Oregon
DecidedNovember 21, 1978
DocketCA 9772
StatusPublished
Cited by3 cases

This text of 586 P.2d 816 (Megdal v. Oregon State Board of Dental Examiners) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Megdal v. Oregon State Board of Dental Examiners, 586 P.2d 816, 37 Or. App. 219, 1978 Ore. App. LEXIS 2128 (Or. Ct. App. 1978).

Opinions

[221]*221JOHNSON, J.

This is an appeal of the Oregon State Board of Dental Examiners’ (Board) order revoking petitioner’s license to practice dentistry. Petitioner practices mostly in Oregon, but also maintains two offices in California, wherein he employs other dentists. Petitioner submitted to an insurance company applications for malpractice insurance for six dentists employed by him in California. The space on the application forms requesting the applicants’ business address had been left blank. The Board found in effect that the business addresses were not disclosed on the applications with the intent of inducing the insurance company to believe the dentists were practicing in Oregon, rather than California, and to issue insurance at premium rates which are less than those prevailing in California. The Board concluded that the non-disclosures constituted both false and fraudulent representations, constituting "unprofessional conduct,” which is grounds for license revocation under ORS 679.140CLXC).1

[223]*223Petitioner makes two assignments which we do not reach.* 2 In his third assignment petitioner contends that the statutory term "unprofessional conduct” as applied to the facts here is unconstitutionally vague. The "void for vagueness” doctrine is primarily applicable to criminal statutes, although it has been applied in administrative law. See Lane County v. Heintz Const. Co. et al, 228 Or 152, 364 P2d 627 (1961). In actuality, the "void for vagueness” doctrine is merely part of the larger body of law concerning the constitutionality of delegation of legislative authority. See Lane County v. Heintz Const. Co. et al, supra; Klein v. Real Est. Comm. Holbrook, 19 Or App 646, 528 P2d 1355 (1974); Gellhorn and Byse, Administrative Law 104 (6th ed. 1974).

As a general proposition the delegation to licensing authorities, including the Board of Dental Examiners, of authority to sanction "unprofessional conduct” has been upheld. See Board of Medical Examiners v. Mintz, 233 Or 441, 378 P2d 945 (1963); Ward v. Ore. State Bd. of Nursing, 266 Or 128, 510 P2d 554 (1973); Hurley v. Board of Dental Examiners, 29 Or App 223, 562 P2d 1229 (1977). These cases are consistent with the trend of judicial authority since 1930, which has been not to invalidate on constitutional grounds broad delegations of legislative authority to administrative agencies. But the fact that courts have been prone to uphold broad legislative delegations does not indicate a lack of judicial concern for the problem. As recently as 1963 the United States Supreme Court divided five [224]*224to four over the issue of whether an act of Congress constituted an overbroad delegation. See Arizona v. California, 373 US 546, 83 S Ct 1468, 10 L Ed 2d 542 (1963). Justice Harlan, writing for three of the dissenting Justices, stated the underlying concern:

"* * * principie that authority granted by the legislature must be limited by adequate standards serves two primary functions vital to preserving the separation of powers required by the Constitution, [footnote omitted] First, it insures that the fundamental policy decisions in our society will be made not by an appointed official but by the body immediately responsible to the people. Second, it prevents judicial review from becoming merely an exercise at large by providing the courts with some measure against which to judge the official action that has been challenged.” (emphasis in original) 373 US at 626, 10 L Ed 2d at 604.

A more concrete manifestation of the judicial concern is the case law where courts have upheld the statutory delegation, but by statutory construction have narrowed the scope of the delegation. See, e.g., Ore. Newspaper Pub. v. Peterson, 244 Or 116, 415 P2d 21 (1966). Cf. Bernard v. Bd. of Dental Examiners, 2 Or App 22, 465 P2d 917 (1970). Alternatively, courts have increasingly subscribed to the concept advanced by Professor Davis that broad delegations of legislative authority are constitutionally permissible, provided the administrative agency adopts rules which circumscribe the delegation in order that affected parties will know the rules of the game and courts can perform a meaningful role upon judicial review. See Davis, Discretionary Justice: A Preliminary Inquiry (1969): Davis, A New Approach to Delegation, 36 U Chi L Rev 713 (1969). Our decision in Sun Ray Dairy v. OLCC, 16 Or App 63, 517 P2d 289 (1973), adopted the Davis approach with respect to the Oregon Liquor Control Commission. In Marbet v. Portland Gen. Elect., 277 Or 447, 561 P2d 154 (1977), the Oregon Supreme Court implied that in the absence of an express legislative direction, it would judicially impose a requirement that an agency with a broad legislative delegation [225]*225adopt rules as a prerequisite to implementing and enforcing its authority. However, in both Marbet and Sun Ray Dairy it was recognized that flexibility is essential. Administrative agencies with broad statutory powers may be required to adopt rules defining the outer perimeters of their authority as a precondition to implementation, but agencies can also rely on case by case adjudication as a means of determining the legality of particular conduct within those perimeters. The seminal case on "unprofessional” conduct is Board of Medical Examiners v. Mintz, supra, which is consistent with Sun Ray Dairy and the implications of Marbet.

In Mintz \he Board of Medical Examiners revoked a physician’s license for allegedly administering drugs to induce an abortion. ORS 677.190 then provided that' it was grounds for revocation for a physician to engage in "unprofessional or dishonorable conduct” and also for "procuring or aiding or abetting in procuring an abortion . . . .”3 The trial court overruled the Board of Medical Examiners on the grounds that the conduct could not constitute "unprofessional or dishonorable conduct” unless the Board had previously adopted rules defining such conduct as unprofessional or dishonorable. The Supreme Court reversed.4 We quote at some length from the court’s opinion:

[226]*226"There is authority for the proposition that a prior formulation of specific standards by the administrative agency is necessary where the grounds for suspension or revocation is cast in broad terms. Sometimes this result is predicated upon the violation of a constitutional right to 'due process’ and sometimes upon the theory that there is an invalid delegation of legislative power. * * *”
"We agree with the view expressed by the court in the Bell case, supra, first in regarding the prior promulgation of rules as unnecessary under the circumstances, and secondly in treating 'unprofessional conduct’ as an adequate standard. We have previously held that the failure to specify in a statute the standards circumscribing administrative actions is not necessarily fatal. It may be advisable for the legislature or the administrative agency to set out specific adjudicatory standards in some instances.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Megdal v. Oregon State Board of Dental Examiners
605 P.2d 273 (Oregon Supreme Court, 1980)
Megdal v. Oregon State Board of Dental Examiners
586 P.2d 816 (Court of Appeals of Oregon, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
586 P.2d 816, 37 Or. App. 219, 1978 Ore. App. LEXIS 2128, Counsel Stack Legal Research, https://law.counselstack.com/opinion/megdal-v-oregon-state-board-of-dental-examiners-orctapp-1978.