Langan v. Board of Registration in Medicine, 76 N.E.3d 995

Langan is a board-certified physician with geriatrics and internal medicine specialties.
In 2008, after testing positive for controlled substances, Langan entered a letter of agreement with the board to abstain from alcohol and drugs and to submit to monitoring.
The letter allowed immediate suspension for violations and guaranteed a right to an adjudicatory hearing.
In 2011, after positive EtG/EtS tests at higher levels, Langan underwent inpatient evaluation and the board directed a temporary stay of practice.
In 2012, Langan signed an addendum requiring attendance at minimum three 12-step meetings per week and proof to PHS; he later misrepresented attendance.
By 2013 the board suspended him for a second time and required monitoring plans as a condition of reinstatement; Langan did not pursue timely review or meet later reinstatement conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2015 reinstatement denial was lawful.	Langan contends the board failed to meet reinstatement conditions.	Board asserts Langan failed to demonstrate abstinence and compliance with monitoring plans.	Yes, the denial was lawful; evidence supported ongoing noncompliance.
Whether the PEth chain of custody issue invalidates board actions.	Langan asserts fraud in testing due to chain of custody errors.	PEth issue did not influence board’s decisions in this matter.	No error; PEth results did not drive the board's determinations.
Whether First Amendment Establishment Clause prohibits requiring 12-step meetings.	Langan argues the requirement imposes a religious framework.	Requirement was part of a voluntary agreement; board would permit secular groups upon request.	No violation; condition was reinstatement-related and secular alternatives were available.
Whether relief under certiorari was proper given procedural history.	Langan seeks stay and reinstatement relief.	Board acted within broad regulatory discretion; no error in denial.	Relief denied; board’s 2015 order within its discretion.

Hoffer v. Board of Registration in Med., 461 Mass. 451 (Mass. 2012) (certiorari review with deference to board expertise)
Sugarman v. Board of Registration in Med., 422 Mass. 338 (Mass. 1996) (board broad authority to regulate medical profession)
Kvitka v. Board of Registration in Med., 407 Mass. 140 (Mass. 1990) (legality of board disciplinary actions; substantial evidence standard)
Indeck v. Clients' Sec. Bd., 450 Mass. 379 (Mass. 2008) (flexible, case-specific certiorari standard; substantial evidence review)
School Comm. of Hudson v. Board of Educ., 448 Mass. 565 (Mass. 2007) (statutory scope of certiorari review and deference to agency decision)