Moore v. State of Maine Bd. of Dental Exam'rs

CourtSuperior Court of Maine
DecidedApril 18, 2008
DocketKENap-07-65
StatusUnpublished

This text of Moore v. State of Maine Bd. of Dental Exam'rs (Moore v. State of Maine Bd. of Dental Exam'rs) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moore v. State of Maine Bd. of Dental Exam'rs, (Me. Super. Ct. 2008).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION

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ROBERT D. MOORE

Petitioner

v. DECISION AND ORDER

STATE OF MAINE BOARD OF DENTAL EXAMINERS,

Respondent

Before the court is petitioner's M.R. Civ. P. 80C petition for judicial review of the

final agency action of the State of Maine Board of Dental Examiners.

By written decision dated October 12, 2007, the Board of Dental Examiners (the

Board) found that petitioner had violated 32 M.R.S.A. § 1077(2)(F)1 by violating the

standard of professional behavior established in the practice of dentistry by providing

dental care that failed to meet minimum accepted standards of practice. Additionally,

the Board found petitioner in violation of 32 M.R.S.A. § 1077(2)(E)2 for failure to provide

dental care that meets the minimum accepted standards of practice. The hearing held

on September 14, 2007 was pursuant to a complaint filed by a patient, NF.

I "Unprofessional conduct. A licensee is considered to have engaged in unprofessional conduct if the licensee violates a standard of professional behavior that has been established in the practice for which the licensee is licensed." 2 "Incompetence in the practice for which the licensee is licensed. A licensee is considered incompetent in the practice if the licensee has: (1) Engaged in conduct that evidences a lack of ability or fitness to perform the duties owed by the licensee to a client or patient or the general public; or (2) Engaged in conduct that evidences a lack of knowledge or inability to apply principles or skills to carry out the practice for which the licensee is licensed." 2

Petitioner is a 58-year-old solo-practitioner dentist practicing in Bangor. NF is a

47-year-old registered nurse employed in the field of infection control. NF was referred

to petitioner for the extraction of a tooth. Petitioner, after concluding that the tooth was

non-restorable, extracted it.

Petitioner "perforated NF's sinus bone during the surgery which resulted in an

oroantral communication or opening between the oral cavity and the maxillary sinus."

It is petitioner's treatment of NF subsequent to perforating the sinus bone that forms the

basis for the Board's finding of unprofessional conduct and incompetence. NF sought a

second opinion and was referred to Dr. Jeffrey Fister (R. Tr. pt. 1 at 20.) Dr. Fister was

at the time a member of the Board. NF made the complaint on the recommendation

and encouragement of Dr. Fister. That complaint details her discussion with Dr. Fister

informing thereby the entire Board of his recommendation. (R. at Index 32 tab 2, p. 9.)

While Dr. Theriault, the original complaint officer recused herself, the complaint was

certainly part of the record adjudicated by the Board. With respect to Dr. Fister, it

stated:

"The first question he asked me was, did you sign a consent about the possible complications? I said no. He then asked, were you told about the complications? I said no. Then he asked did Dr. Moore take x-rays? ..! told him that Dr. Moore had me packing with gauze ...that's when Dr. Fister said, STOP packing with the gauze!...You should not be packing at all. How do you know you're getting all of the pieces out??!! He said that packing could become lodged up in there and the area can't drain ...Then I said, Dr. Fister, .. .I want to know what you think I should do ...Dr. Fister said, since you've asked me I would recommend you file a complaint with the Maine Board of Dental Examiners." ld.

Dr. Fister testified at the hearing being called as an expert witness by the attorney

prosecuting the claim against petitioner. (R. Index 1-31 tab 6; Tr. pt. 1 at 299.) Dr.

Fister's testimony reveals multiple instances in which he compared the work of

petitioner with what he would have done, at one point being told by the hearing officer, 3

"You've got to stop saying what you would have done and you've just gotta testify to

what you saw ..." (R. Ir. pt. 1 at 311.) Further, in his closing argument, the AAG

stressed the importance of weighing the relative credibility of witnesses and compared

the work of petitioner and Dr. Fister, "had an appropriate radiograph been taken, such

as Dr. Fister's, the root tip would have been visualized and the patient conformed,

hopefully." (R. Ir. pt. 2 at 276-29.) Dr. Fister's testimony had an effect on the decision

of at least Dr. Higgins, who had earlier made a sarcastic comment in reference to Dr.

Fister recusing himself from the board for this case. (R. Ir. pt. 1 at 115-16; pt. 2 at 309­

10.) Further, Dr. Moyer, the Board's only other oral surgeon besides Dr. Fister, recused

himself. As a result, petitioner's case, which focused on the standard of care to be given

by an oral surgeon was heard by a Board comprised of no oral surgeons. (R. Index 34 at

6.)

Standard of Review:

"An administrative process may be infirm if it creates an intolerable risk of bias

or unfair advantage." Zegel v. Board of Social Work Licensure, 2004 ME 31,

18,22.

Discussion:

Petitioner argues that Dr. Fister's pre-complaint involvement and strong

encouragement, and the Board's knowledge of his involvement and encouragement,

make it highly probable that his case was heard by a tribunal susceptible to a risk of

bias or unfairly predisposed against him.

/I A combination of investigative and adjudicatory functions in administrative

proceedings generally does not violate due process absent some further showing of bias

or risk of bias." [d. n. 3 (citing Withrow v. Larkin, 421 U.s. 35 (1975)). However, the Law 4

Court has said in dictum, "the combination of investigator, prosecutor and sitting

member of the adjudicatory panel, even if ostensibly a nonparticipating member, creates an

intolerably high risk of unfairness." Id. (quoting Gashgai v. Bd. of Registration in Med.,

390 A.2d 1080, 1082 n. 1 (Me. 1987) (emphasis added)). While Dr. Fister was not himself

the investigator or prosecutor, his role as a sitting board member combined with his

pre-complaint treatment of NF, his role in advising NF to file a complaint, his expressed

opinions of the efficacy of the complaint as seen by the Board, and his designation as an

expert witness in front of a Board on which he sat, combine to create an intolerable risk

of bias or unfairness.

In Zegel the Court held that it "need not determine whether the process here

crossed the line because the error, if any, was harmless." Id. at

This court cannot say that error in this instance was harmless. The gloss put on the facts

by the Board was impacted by the knowledge that an important and influential member

of the Board believed this case to constitute a violation, treated the patient, acted as a

witness in front of the Board, and was the person who recommended to the petitioner

that she file a complaint to the Board. Buttressing this risk is that the Board was acting

without an oral surgeon. Had Dr. Fister not been involved in treatment and had not

advised NF to file a complaint, his expertise would have very likely been an invaluable

asset to the Board's deliberations. Given the circumstances, the risk of a tribunal

operating without the benefit of their highly knowledgeable colleague giving more

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Related

Zegel v. Board of Social Worker Licensure
2004 ME 31 (Supreme Judicial Court of Maine, 2004)
In Re Maine Clean Fuels, Inc.
310 A.2d 736 (Supreme Judicial Court of Maine, 1973)
Gashgai v. Board of Registration in Medicine
390 A.2d 1080 (Supreme Judicial Court of Maine, 1978)

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