Friedman v. Kansas State Board of Healing Arts, 294 P.3d 287

Friedman obtained a Kansas medical license in 1999 and paid renewals for several years.
In 2006 he requested inactive status and did not pay the 2006 renewal fee.
The Board filed formal disciplinary action July 31, 2006, seeking license revocation.
Friedman contended the Board lacked jurisdiction since his license had expired.
The Board argued jurisdiction depended on misconduct timing, not license status at filing.
The court held the Board had jurisdiction because misconduct occurred while Friedman was practicing under the Act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Board jurisdiction despite license expiry	License expired before petition; no jurisdiction.	Jurisdiction hinges on misconduct during licensure, not license status at filing.	Board had jurisdiction to initiate disciplinary action.
Due process argument preservation	Oral argument rights were improperly denied.	Issue waived for lack of briefing and authority.	Due process issue waived; not considered.
Substantial evidence for Board findings	Evidence not substantial; errors in credibility and weight.	Evidence substantial; Board credibility determinations valid.	Board findings supported by substantial evidence under pre-2009 standard.

Ryser v. State, 295 Kan. 452 (2012) (board jurisdiction under Act requires considering timing of misconduct)
Friedman v. Kansas State Bd. of Healing Arts, 287 Kan. 749 (2009) (Friedman I; jurisdiction and exhaustion issues discussed)
Blue Cross & Blue Shield of Kansas, Inc. v. Praeger, 276 Kan. 232 (2003) (arbitrary and capricious findings analyzed under substantial evidence standard)
Frick Farm Properties v. Kansas Dept. of Agriculture, 289 Kan. 690 (2009) (standard of review: substantial evidence; credibility not reweighed)
State v. Herron, 286 Kan. 959 (2008) (circumstantial evidence can support civil findings)
Friedman v. Kansas State Bd. of Healing Arts, not applicable (not applicable) (case referenced as Friedman I; included for context)