506 F. App'x 342
6th Cir.2012Background
- Plaintiff Dr. Bradford A. Quatkemeyer alleged mail fraud and due process violations under 42 U.S.C. § 1983 against the Kentucky Board of Medical Licensure.
- A grievance against Quatkemeyer in 2007 claimed improper and excessive prescription of controlled substances enabling illegal drug use.
- The Board investigated, issued an Emergency Order of Restriction, then a Probation Order against Quatkemeyer; he requested a hearing and the Board affirmed its decision after the hearing.
- Quatkemeyer pursued state-court review; a Temporary Injunction was denied and state court decisions were affirmed; federal suit was filed the same day in district court.
- The district court abstained under Younger for constitutional claims and dismissed the mail-fraud claim against the Board as a state agency entitled to Eleventh Amendment immunity; after state decision, it dismissed the remaining claims, noting possible quasi-judicial immunity for individual Board members.
- On appeal, Quatkemeyer challenges the district court’s abstention posture and whether Board members are entitled to quasi-judicial immunity; the court affirms on alternative grounds, finding quasi-judicial immunity for Board members.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Board members entitled to quasi-judicial immunity? | Quatkemeyer argues immunity does not apply to individual Board members. | Board contends members perform adjudicatory duties warranting quasi-judicial immunity. | Yes; Board members have quasi-judicial immunity. |
Key Cases Cited
- Butz v. Economou, 438 U.S. 478 (1978) (absolute immunity for officials performing functions analogous to prosecutorial/adjudicatory roles)
- Watts v. Burkhart, 978 F.2d 269 (6th Cir. 1992) (independence of professional board members supports immunity)
- Cleavinger v. Saxner, 474 U.S. 193 (1985) (disciplinary bodies lacking independence may fail to confer immunity)
- Forrester v. White, 484 U.S. 219 (1988) (functional approach to immunity based on function performed)
- Bush v. Rauch, 38 F.3d 842 (6th Cir. 1994) (prosecutorial-like functions justify immunity for quasi-judicial roles)
- Collyer v. Darling, 98 F.3d 211 (6th Cir. 1996) (functional immunity analysis focuses on nature of act, not actor)
- Bettencourt v. Bd. of Registration in Med. of Mass., 904 F.2d 772 (1st Cir. 1990) (immunity balanced with safeguards in professional boards)
- Horwitz v. State Bd. of Med. Exam’rs of Colo., 822 F.2d 1508 (10th Cir. 1987) (board composition can support immunity when independent professionals)