STATE OF NORTH DAKOTA

COUNTY OF BURLEIGH 

IN DISTRICT COURT

SOUTH CENTRAL JUDICIAL DISTRICT

CIVIL NO. 00 -C-1322

Dr. Brian D. Gale,  )
 )

Appellant,

 )
 )

vs.

)        Dr. Gale’s Brief on Appeal
) of the Board’s Administrative Decision
North Dakota Board of Podiatric )
Medicine, )
)

Appellee.

)

 

This is Dr. Gale’s brief in support of his appeal of the North Dakota Board of Podiatric Medicine’s (Board) administrative decision against Dr. Gale dated February 2, 2000. Dr. Gale hereby incorporates Tab Exhibits 1 through 36 that were attached to Dr. Gale’s brief in support of his motion for stay dated March 8, 2000 as part of this brief as if attached. [The reason for incorporating these Tab Exhibits here is to avoid duplication and also to avoid making the record any larger than it already is.]

Standard for Appeal to the District Court

The standard for appeal to the district court is set out in section 28-32-19, N.D.C.C. as follows:

A judge of the district court must review an appeal from the determination of an administrative agency based only on the record filed with the court. After a hearing, the filing of briefs, or other disposition of the matter as the judge may reasonably require, the court must affirm the order of the agency unless it shall find that any of the following are present:

  1. The order is not in accordance with the law.

  2. The order is in violation of the constitutional rights of the appellant.

  3. Provisions of this chapter have not been complied with in the proceedings before the agency.

  4. The rules or procedure of the agency have not afforded the appellant a fair hearing.

  5. The findings of fact made by the agency are not supported by a preponderance of the evidence.

  6. The conclusions of law and order of the agency are not supported by its findings of fact.

This Court in its Memorandum Opinion dated April 25, 2000, page 2, stated that section 28- 32-19 gives considerable deference to the findings of the "agency". This Court then cites to Gale v. North Dakota Bd. of Podiatric Medicine, 1997 ND 83, 562 N.W.2d 878 as an example of the extent to which the North Dakota Supreme Court has gone to uphold the rulings of administrative agencies. It is important to point out that in Gale v. North Dakota Bd. of Podiatric Medicine the Supreme Court at ¶10 or page 881 cites to section 28-32-19 as the standard of review of an administrative agency and at page 882 the Supreme Court states, "Our review of the Board’s findings is limited to whether a reasoning mind reasonably could have determined the findings were proven by the weight of the evidence from the entire record." It is also critical to remember that Gale v. North Dakota Bd. of Podiatric Medicine involved an administrative hearing where there was a hearing officer presiding who heard testimony and considered documentary evidence whereas in the present case there was no hearing officer and there was no testimony. Rather there were only the four members of the Board purportedly read the briefs of the Board and of Dr. Gale and who allegedly reviewed documentary evidence. Further there is no language in Gale v. North Dakota Board of Podiatric Medicine which states that the ND Supreme Court gave any deference to the finding of the agency. Rather the Supreme Court at ¶39 or page 887 and again at ¶44 or page 887 bases its holding on the grounds that a reasoning mind could have arrived at the same decision that the Board came to.

In Re Juran and Moody, Inc., 2000 ND 136, ¶24, 613 N.W.2d 503, 509 involved an administrative hearing wherein a hearing officer was appointed to hear the case. The North Dakota Supreme Court stated that "Here, deference to the ALJ’s factual findings is warranted. The ALJ had the opportunity to observe the witnesses and the ‘responsibility to assess the credibility of witnesses and resolve conflicts in the evidence.’" (Citation omitted) Additionally, the ND Supreme Court in In Re Juran and Moody, Inc., at ¶25 and page 510 stated, "Regarding review of an agency’s legal conclusions, we have indicated an agency ‘has a reasonable range of informed discretion in the interpretation and application of its own rules.’" Further at ¶27 the court held:

We accordingly hold where an agency requests the OAH designate an ALJ to issue a final decision, judicial review of the ALJ’s factual findings should involve the standard of review used for agency decisions, but the ALJ’s legal conclusions must be reviewed in the same manner as legal conclusions generally, without special deference to the ALJ.

Since the case now before the Court involves a situation where there was neither an ALJ nor a Board had the opportunity to observe witnesses and determine their credibility and resolve conflicts in the evidence, there then is no basis for this Court to provide the Board’s decision with any deference. Accordingly, the Court must apply instead the test of whether a reasoning mind reasonably could have determined that the findings were proven by the weight of the evidence in the record.

The court in Volesky v. North Dakota Game and Fish Dept., 1997 ND 140, ¶7, 566 N.W.2d 812, 815 stated:

Under N.D.C.C. § 28-32-19, our review involves a three-step process to decide whether the Board’s findings of fact are supported by a preponderance of the evidence, its conclusions of law are supported by its findings of fact and its decision is supported by its conclusions of law and is in accordance with the law. (Citation omitted). In reviewing the Board’s findings of fact, we do not make independent findings or substitute our judgment for that of the Board; instead, we decide whether a reasoning mind could have reasonably decided the Board’s factual conclusions are supported by the weight of the evidence.

The court in Rudolph v. Dept. of Transp. Director, 539 N.W.2d 63, 66 (N.D. 1995) held that "In determining whether an agency’s findings of fact are supported by a preponderance of the evidence, the standard of review is whether a reasoning mind could reasonably have determined the factual conclusions were supported by the weight of the evidence."

The court in Kuklock v. N.D. Workers’ Comp. Bureau, 492 N.W.2d 572, 574-575 (N.D. 1992) held that:

When there is inconsistent medical evidence, the Bureau cannot rely upon evidence favorable to its position without attempting to clarify the inconsistencies. (Citation omitted). Although the Bureau may weigh and resolve conflicting medical opinions, the Bureau must adequately explain its reason for disregarding evidence favorable to the claimant. (Citation omitted). The Bureau must explain why it is relying upon medical evidence supporting a denial of benefits, rather than upon conflicting medical evidence that supports an award of benefits (Citation omitted).

 

Dr. Gale’s Basis for Appeal and Statement of the Issues

Dr. Gale’s specification of error on appeal includes appealing the Board’s findings of fact since the Board breached the agreement with Dr. Gale to " . . . review all those briefs and documents, including x-rays, which were provided to and reviewed by Adolph W. Galinski . . .". Rather the reviewing Board members did the following: (a) based their findings of fact and conclusions of law on matters not in the record, (b) ignored matters that were in the record which the Board mistakenly stated were not in the record, (c) failed to consider all of the briefs, documents, facts and arguments made by Dr. Gale and failed to consider the opinion of Dr. Gale’s expert witness ( Dr. Vogler), (d) considered matters that were outside the scope of the First Amended Complaint, (e) failed to set forth and define what is the standard of practice and how is such standard of practice determined, (f) imposed discipline that has made it financially impossible for Dr. Gale to pay in order to retain his license in Podiatric Medicine and to continue to earn a living in his chosen field, (g) stated at the Board hearing on January 27, 2000 that Dr. Gale would be able to complete all of the retraining requirements within three months when in fact it will take more than three times that amount of time (i.e., more than nine months) to complete with such retraining financially unachievable for Dr. Gale due to his limited financial condition. (Dr. Gale has already secured additional loans and Dr. Gale has already expended the greater part of his retirement account in order to pay for the retraining required by the Board, the necessary legal fees to defend against the Board’s allegations and for living expenses necessary to support his family).

Procedural History

On June 12, 1995, Dr. Philip Q. Johnson of Fargo sent a letter (Tab 2) to Dr. Hofsommer of the Board concerning a patient, Geraldene Parsley, who Dr. Gale had operated on for a torn Achilles tendon and Dr. Johnson thought that perhaps the surgery was unnecessary. On December 20, 1995, the CEO of the Bone & Joint Center, P.C. sent a letter (Tab 3) to Gary R. Thune as counsel for the Board asking that four cases involving Dr. Gale be looked into because the doctors at the Bone & Joint Center thought there may be departures from the proper standards of care. These four cases involved: (1) Corrine High Elk, (2) Gwyn Herman, (3) Patricia Lautenschlager and (4) Margie Pulkrabek. On August 23, 1997, the Board filed a complaint (Tab 4) against Dr. Gale alleging that he violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by failing to properly treat and care for (1) Patricia J. Laughtenschlager, (2) Gwyn Herman, (3) Corrine N. High Elk, (4) Patty Greer, (5) Margie A. Pulkrabek, (6) Geraldene Parsley, and (7) Cheryl Wetzstein. On April 20, 1998, the Board filed a First Amended Complaint (Tab 5) which alleged that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. against (1) Patricia J. Lautenschlager, (2) Gwyn Herman, (3) Patty Greer, (4) Margie A. Pulkrabek, (5) Geraldene Parsley, (6) Cheryl Wetzstein, (7) Gladys Wright and (8) Shirley Sailer.

On June 22, 1998, the Board and Dr. Gale entered into a Settlement Agreement (Tab 6) wherein Dr. Gale waived his right to an administrative hearing since the Board and Dr. Gale both wanted to resolve this matter without an administrative hearing due to the voluminous medical information that a hearing officer would have difficulty understanding and also in order to save money. In this Settlement Agreement, the parties agreed to have an independent expert reviewer (selected by the parties) who would make factual findings regarding whether Dr. Gale failed to properly treat and care for the patients and the parties agreed that the independent reviewer’s factual findings would be binding on both the Board and Dr. Gale and not appealable. The parties agreed to have Dr. Adolph W. Galinski, Associate Dean, Clinical Sciences, Scholl College of Podiatric Medicine, Chicago, Illinois serve as the independent reviewer.

On May 10, 1999, the Board filed their opening brief with Dr. Galinski. The Board hired Dr. E. Dalton McGlamry as its expert witness. In the Board’s brief (dated May 10, 1999), the Board withdrew its complaints against Dr. Gale as relates to patients (1)Cheryl Wetzstein, (2)Gwyn Herman and (3) Patty Greer. As a result of withdrawing these three complaints there were five complaints left, namely: (1) Patricia Lautenschlager, (2) Geraldene Parsley, (3) Margie Pulkrabek, (4) Shirley Sailer, and (5) Gladys Wright. On June 22, 1999, Dr. Gale filed his brief with Dr. Galinski. Dr. Gale hired Dr. Harold Vogler as his expert witness. On July 9, 1999, the Board filed its reply brief with Dr. Galinski.

On July 20, 1999, Dr. Galinski issued his opinion (Tab 7) concluding that in all five cases that Dr. Gale failed to properly treat and/or care for the patient. However, in his written opinion, Dr. Galinski discussed in great detail that Dr. Gale’s medical record keeping in all five cases was unacceptable. At a Board meeting on August 11, 1999 in Jamestown, the Board and Dr. Gale entered into a Stipulated Modification to Settlement Agreement (Tab 8) since Dr. Galinski’s opinion discussed in detail Dr. Gale’s medical record keeping in all five cases and medical record keeping was not even an issue in the First Amended Complaint; thus it was agreed by the parties to not accept Dr. Galinski’s opinion. At the August 11, 1999 meeting in Jamestown, Dr. Gale provided information to the Board that his medical records had been audited by Blue Cross and Blue Shield twice with the latest audit being done in June 1997 and that both times the Blue Cross and Blue Shield medical record audits found Dr. Gale’s medical records adequate. Dr. Gale also provided information to the Board at the August 11, 1999 meeting in Jamestown that St. Alexius Medical Center had conducted an independent review by hiring Dr. Steven Kilwein to review 90 charts of Dr. Gale’s concerning operations that Dr. Gale had performed at St. A’s. This independent review conducted by St. Alexius determined that there were no concerns with any of the 90 surgeries Dr. Gale had performed at St. A’s. The parties stipulated that four members of the Board (Dr. Hofsommer, Dr. Stone, Dr. Deckert and Dr. Moen) would now act as independent reviewers in place of Dr. Galinski. Dr. Gale was given the choice of accepting Dr. Galinski’s decision or of allowing the Board members to review all the records and briefs. This was the only option given Dr. Gale. The President of the Board, Dr. Aaron Olson, was not permitted to be an independent reviewer due to the on-going hostility and animosity between Dr. Olson and Dr. Gale. Notably, however, Dr. Olson was present at this August 11, 1999 Board meeting and Dr. Olson continued to communicate with other Board members during the meeting. This August 11, 1999 stipulation between the parties specifically defined the role of the new reviewers stating that they : " . . . shall review all those briefs and documents, including x-rays, which were provided to and reviewed by Adolph W. Galinski, following which the reviewers may exercise the option of either making further oral inquiry of Dr. Brian Gale or making factual findings regarding whether Gale failed to properly treat and care for patients. The new independent reviewers’ factual findings will be binding on both the Board and Gale, and not appealable." (Emphasis added)

On January 12, 2000, the Board had a meeting where all of the four Board members were on a telephone conference call with the Board’s attorney, Mr. Thune, and where Dr. Gale and the undersigned were present. The Board failed to ever refer to or even discuss the first amended complaint at this Board meeting. Further the Board also failed to ever discuss what the standard of care actually was for each of the five complaints or to define what the standard of care was and whether they had ever given Dr. Gale proper notice of the issues that they were considering as part of their disciplinary decision. The purpose of this meeting was for the four Board members to arrive at their findings of fact. The Board made no provision to record this meeting; fortunately, Dr. Gale had a tape recorder with him and Dr. Gale recorded the entire Board meeting. The Board allowed neither Dr. Gale nor the undersigned to speak at this meeting even though there were errors and misstatements being made by the Board. The Board’s attorney, Mr. Thune, did then allow Dr. Gale to provide him with a prepared written presentation which Mr. Thune then mailed to the four Board members sometime after the Board meeting. After this Board meeting on January 12, 2000, Mr. Thune prepared Recommended Findings, Conclusions and Order. Mr. Thune mailed to the Board his recommended findings along with, Dr. Gale’s written statement and his medical records which were critical for the Board to review; especially, in light of some of the misstatements that the Board had made at the January 12, 2000 meeting. Mr. Thune also allowed Dr. Gale to present to the Board a written summary of the errors that the Board had made at the January 12, 2000 Board meeting, which summary also referenced the medical records that the Board failed to even consider or chose to simply ignore.

 

On January 27, 2000, the four Board members had another meeting whereby they considered Mr. Thune’s Recommended Findings, Conclusions and Order; they also stated at this January 27, 2000 meeting that they had considered Dr. Gale’s written summary of the errors that the Board had made at the January 12, 2000 Board Meeting. The Board dropped-out findings of fact paragraphs 4 and 6 of the Recommended Findings, Conclusions and Order prepared by Mr. Thune prior to the January 27, 2000 Board meeting. On February 2, 2000, the Board served upon the undersigned Findings, Conclusions and Order Imposing Discipline (Tab 1).

Standard of Care

It is critical here at the outset to point out for the Court a major error in the Board’s findings of fact, conclusions and order. The Board completely failed to set forth the necessary standard of care in its findings, conclusions and order. This failure alone is sufficient grounds in and of itself to warrant reversal of the Board’s decision. The standard of care as relates to Dr. Gale’s treatment of all five patients is a threshold issue in each case. Section 43-05-16(1)(k), N.D.C.C. states, "Engaging in unprofessional conduct that includes any departure from or the failure to conform to the minimal standards of acceptable and prevailing podiatric medical practice." (Emphasis added) This North Dakota statute requires the Board to set forth what is the "...the minimal standards of acceptable and prevailing podiatric medical practice." The minimal standard is something less than the accepted standard of care (e.g., much like a grade of C which has a range of 70 to 79 with the minimum grade of 70 also a C). The Board’s findings of fact and conclusions fail to even state what the standard of care is much less, what the minimal standard of care is for each of the five complaints. Establishing the standard of care and the minimum standard of care in each of the five complaints is a statutory requirement. In addition, the four Board members who were sitting as independent reviewers in the case at bar lack the required background in surgery to establish what the standard of care was for each of the five surgeries/complaints much less, to determine what the minimum standard of care is. As set forth in Dr. Gale’s attached affidavit (Tab 36), Dr. Robert Deckert has no surgical residency training in foot and ankle surgery, Dr. Lee Hofsommer has one year of surgical residency training in foot and ankle surgery, Dr. Mike Stone has one year of surgical residency training in foot and ankle surgery and Dr. Doug Moen has no surgical residency training in foot and ankle surgery; while the appellant, Dr. Gale, has four years of surgical residency training in foot and ankle surgery. How is it possible for any of these four Board members to determine and to make a qualified judgment as to the standard of conduct or the minimum standard of conduct necessary in each of the five surgeries/complaints as relates to Dr. Gale’s performance when, in fact, Dr. Gale’s qualifications are so much higher than any of the four Board members? Not one of the four Board members is qualified to make that determination i.e., to determine the standard of care or the minimum standard of care involved in each of the five surgeries that Dr. Gale performed. Thus by necessity, the Board would have to resort to and rely upon the two expert witnesses that were employed by both the Board and by Dr. Gale in order to make such a determination. The Board hired an expert witness, Dr. McGlamry, and Dr. Gale hired an expert witness, Dr. Vogler. Dr. McGlamry discusses the standard of care in his opinion and Dr. McGlamry’s opinion is contained as part of the Board’s brief filed with the independent reviewer (May 10, 1999). Dr. Vogler discusses at length the standard of care in his opinion. Significantly, Dr. Vogler also had the opportunity to review Dr. McGlamry’s opinion and to then respond to Dr. McGlamry’s opinion that Dr. Gale’s surgeries were below the standard of care. In doing so, Dr. Vogler also referred to and set forth for the Board professional literature in the field of podiatry which clearly discounted Dr. McGlamry’s statements about the standard of care and to further point-out for the Board where Dr. McGlamry had the facts confused. In addition, Dr. Vogler even referenced in his expert report a specific textbook that was actually authored by Dr. McGlamry which in fact refutes Dr. McGlamry’s own conclusion that Dr. Gale’s conduct was below the accepted standard of care. Dr. Vogler’s entire opinion and verifiable, supportive professional literature is included in the brief submitted earlier (June 22, 1999) by Dr. Gale to the independent reviewer (Dr. Galinski). In contrast, the Board’s expert’s opinion (i.e., Dr. McGlamry’s opinion) as to the standard of care is unsupported by any reference to any authoritative literature in the field of podiatry. Here it is also important to point out for the Court that Dr. Aaron Olson, the Board’s President, has known Dr. McGlamry for at least twenty-five years (See: Attached affidavit of Dr. Olson) (Tab 9 ). Dr. Gale respectfully submits that this relationship between Dr. Olson and Dr. McGlamry taints Dr. McGlamry’s entire opinion throughout and thus renders Dr. McGlamry’s opinion unfair at best and at worst, flagrantly bias. Of critical importance here, is that Dr. Vogler’s conclusion on page 23 of his opinion states, "Dr. Gale’s performance on the above five patients is clearly within the standard of care for a podiatrist and as such, his conduct does not fall within Section 43-05-16(1)(g), (k) or (u), N.D.C.C." (Emphasis added) Further the Board’s reply brief dated July 9, 1999 includes no comments whatsoever from Dr. McGlamry in any way criticizing this conclusion by Dr. Vogler concerning the proper standard of care. The Board’s reply brief does disagree with Dr. Vogler’s conclusions; yet, there is not a single reference in the Board’s reply brief as to any comment from its own expert (Dr. McGlamry) ever disagreeing with Dr. Vogler’s opinion as to the proper standard of care. Also absent from the Board’s reply is any reference whatsoever to supportive professional literature in the field of podiatry that is in any way consistent with the Board’s decision.

 

The Board failed to set forth in its findings, conclusions and order imposing discipline that it even considered either Dr. McGlamry’s or Dr. Vogler’s opinions in arriving at a standard of care or a minimum standard of care. Accordingly, the Board’s failure to set forth the standard of care and the minimum standard of care in the case at bar is fatal to the Board’s findings of fact, conclusions and order. This Board has never defined the standard of care or the minimum standard of care in any statute or administrative ruling; as such, the proper standard of care must be determined by expert testimony. Notably, in medical malpractice cases, the plaintiff is required to establish the standard of care through an expert witness who regularly practices in that particular specialty. The court in Larsen v. Barrett, 498 N.W.2d 191, 192 (N.D. 1993) stated, "A prima facie case of medical malpractice consists of expert evidence establishing the applicable standard of care, violation of that standard, and a causal relationship between the violation and the harm complained of." (Emphasis added) The court in Benedict v. St. Luke’s Hospitals, 365 N.W.2d 499, 502-503 (N.D. 1985) stated, "A medical specialist must exercise the care and skill ordinarily possessed and exercised by, and reasonably expected of, other specialists engaged in similar practice." and further, "The standard of care for a physician who is not considered as a medical specialist is that he must exercise the care and skill ordinarily possessed and exercised by, and reasonably expected of, other physicians engaged in similar practice." The four Board members who sat as the finders of fact in the present case were not qualified to determine what the standard of care is or what the minimum standard of care is for the five surgeries performed by Dr. Gale, since none of the four Board members have a similar practice or a similar education to that of Dr. Gale in performing the foot and ankle surgeries that are involved in the five complaints. Accordingly, the only way the four Board members could determine the standard of care and the minimum standard of care for Dr. Gale as relates to the five surgeries in the complaints that Dr. Gale performed is by reference to the two expert witnesses. The Board must also be certain when making any determination that there is a proper connection between that expert’s opinion and the First Amended Complaint, since the expert’s opinion must relate only to the allegations contained within the First Amended Complaint. The Board’s expert, Dr. McGlamry, in his opinion makes numerous and detailed references to Dr. Gale’s medical records, an issue that is not even in the First Amended Complaint. Dr. McGlamry considering an issue not even in the First Amended Complaint plus Dr. McGlamry’s 25 year friendship with Dr. Olson, President of the Board, (who has been prohibited from participating in this case) should essentially disqualify Dr. McGlamry’s opinion. On the other hand, Dr. Vogler in his review and in his report provided to the Board clearly sets forth the First Amended Complaint for each of the five complaints against Dr. Gale. Further Dr. Vogler’s analysis of each patient’s case is always done from the perspective of the First Amended Complaint and Dr. Vogler decidedly reviewed the records and authoritative professional literature prior to arriving at his opinion that Dr. Gale’s conduct clearly was within the standard of care for a podiatrist in each of the five surgeries/complaints.

 

The Board’s failure to make a finding of fact concerning the standard of care or the minimum standard of care based upon either of the two expert witnesses is fatal to the Board’s findings of fact and conclusions; and therefore, the findings of fact and conclusions and order of the Board should be reversed. As set out on page 2 of Brief of Dr. Brian Gale (filed with the Board on June 22, 1999), the Board has the burden of proof to establish that Dr. Gale violated state law by the greater weight of the evidence. Likewise this burden of proof also applies to the Board in proving the standard of care and the minimum standard of care. Consequently, since the Board has failed in this burden, the Board’s decision against Dr. Gale should be reversed.

 

As set forth above, the court in Kuklock v. N.D. Workers’ Comp. Bureau, supra, and the cases cited therein held that when there is inconsistent medical evidence, the Bureau could not rely upon evidence favorable to its position without attempting to clarify the inconsistencies. In addition, the Bureau was required to explain why it relied upon medical evidence supporting a denial of benefits rather than upon conflicting medical evidence that supports an award of benefits. Accordingly, in the present case, the Board cannot ignore the opinion evidence of Dr. Vogler that Dr. Gale’s performance on the five patients listed in the Complaint is clearly within the standard of care for a podiatrist without the Board attempting to clarify its inconsistent decision that Dr. Gale’s conduct falls below the minimal standards of acceptable and prevailing podiatric medical practice. The Board’s failure to even address the standard of care issue is basis alone to reverse the decision of the Board.

Denial of Due Process

A second issue concerning the Board’s conduct is that the Board considered matters outside the scope of the First Amended Complaint and as such, the Board denied Dr. Gale notice of the issues to be considered thereby constituting a denial of due process to Dr. Gale. This denial of due process must be discussed prior to any analyses of the five complaints. Like the standard of care issue set forth above, the denial of due process to Dr. Gale permeates the Board’s entire decision. In this brief (section entitled Analyses of the Five Complaints), Dr. Gale sets forth for the Court how in each of the five complaints the Board raises new issues after the record was closed; such conduct by the Board denied Dr. Gale due process of law. The court in Devous v. Bd. Of Medical Examiners, 845 P.2d 408, 415-417 (Wyo. 1993) found that a disciplinary proceeding before a licensing board is an adversary proceeding and that a licensee has a statutory and constitutional right to notice from the agency and an opportunity to be heard before the agency. Furthermore that the due process clauses of both the United States Constitution and the Constitution for the State of Wyoming demand these minimal guarantees. The Devous decision, at page 415, citing from an Iowa case, Gilchrist v. Bierring, 14 N.W.2d 724, 732 (Iowa 1944), stated that :

The cases, from which we have quoted, clearly announce fundamental principles, essential to the life of a free people living under a republican form of government. The right to earn a living is among the greatest of human rights and, when lawfully pursued, cannot be denied. It is the common right of every citizen to engage in any honest employment he may choose, subject only to such reasonable regulations as are necessary for the public good. Due process of law is satisfied only by such safeguards as will adequately protect these fundamental, constitutional rights of the citizen. Where the state confers a license to engage in a profession, trade, or occupation, not inherently inimical to the public welfare, such license becomes a valuable personal right which cannot be denied or abridged in any manner except after due notice and a fair and impartial hearing before an unbiased tribunal. Were this not so, no one would be safe from oppression wherever power may be lodged, one might be easily deprived of important rights with no opportunity to defend against wrongful accusations. This would subvert the most precious rights of the citizen. (Emphasis added).

Slagle v. Wyoming State Bd. of Nursing, 954 P.2d 979, 982-983 (Wyo. 1998) was a case where the Board of Nursing filed a complaint against Slagle and then the Board of Nursing rendered its decision considering (1) an alleged violation of a cease and desist order and (2) allegations that Slagle made false statements on her 1993 application, neither of which were in the complaint filed by the Board. The Wyoming Supreme Court held that the Board failed to give Slagle notice that the Board would consider these two alleged violations as a basis for discipline and such failure to give Slagle notice was unconstitutional. The Wyoming Supreme Court reversed the Board’s decision to discipline Slagle. The Slagle case is similar to the case now before the Court since in the present case the Board considered new issues after the record was closed thereby denying Dr. Gale the opportunity to provide evidence, including an expert opinion on these new issues; and as such, the Board has violated Dr. Gale’s constitutional rights.

In North Dakota, the court in Morrel v. North Dakota Dept. Of Transp., 1999 ND 140, ¶9, 598 N.W.2d 111 states, "Due process requires a participant in an administrative proceeding be given notice of the general nature of the questions to be heard and an opportunity to prepare and be heard on those questions. (Citation omitted) Notice is sufficient if it informs the party of the nature of the proceedings so there is no unfair surprise." There is no doubt in the present case that the Board raised many new issues after the record was closed thereby denying Dr. Gale notice of these issues, denying Dr. Gale an opportunity to address these new issues and denying Dr. Gale’s expert witness the opportunity to address these new issues. Consistent with the Devous and Slagle courts, Dr. Gale’s license to practice podiatry is a valuable personal right and a right in which Dr. Gale has invested substantial money and over 20 years of his life with an expectation that such an investment will provide he and his family with a living. The Board has denied Dr. Gale his right of due process by raising new issues after the record was closed; accordingly, the Board’s decision against Dr. Gale is unconstitutional and should be reversed.


Analyses of the Five Complaints

Patricia Lautenschlager:

The Board’s first amended complaint dated April 20, 1998 against Dr. Gale as relates to Patricia Lautenschlager states that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by:

a. failing to properly treat and care for Patricia J. Lautenschlager. Dr. Gale performed an ankle fusion of the right ankle and a procedure to remove a portion of the medial malleous and reposition pins from the external fixator in March 1993. As a result of the procedures, the ankle was in a position of varus, and the tibia was posteriorly displaced on the talus. Dr. Gale performed a calcaneal osteotomy in March 1994, resulting in residual varus of the foot and pain in the subtalar joint.

The Board’s Findings of Fact dated February 2, 2000 as relates to Patricia Lautenschlager states as follows:

  1. Dr. Gale failed to intra-operatively recognize complications critical to surgical outcome, specifically in the assessment of anatomical position before closure, which created an unnecessary risk of damage to the patient’s health and safety.
  2. Subsequent to the first operation, the limited subtalar joint motion does not support a calcaneal osteotomy as the proper procedure.
  3. The follow-up procedure, relative to the varus position was ineffective.

At the outset, it should be noted that the complaint as to Patricia Lautenschlager originated from the Bone & Joint Center, P.C. December 20, 1995 letter to the Board. Dr. Gale performed four surgeries on Ms. Lautenschlager. The first surgery was on March 1, 1993 for an ankle fusion (arthrodesis). The second surgery was on March 26, 1993 for removal of medial malleous and reposition of the pins. The third surgery was on May 28, 1993 to remove the pins after the fusion was healed. The fourth surgery was on March 21, 1994 to reposition the heel bone (heel varus). The Board’s first finding of fact does not even specify to which of the four operations it is referring to. Based upon the Board’s second finding of fact, it would appear that the Board’s first finding of fact is referencing the first surgery on March 1, 1993.

It becomes imperative here to point out for the Court that the Board’s President, Dr. Aaron Olson, assisted Dr. Gale in this March 1, 1993 operation (Tab 10). Yet, and very conspicuously missing, the Board has failed to take any disciplinary action whatsoever against Dr. Olson. The Board has chosen instead to focus all of its blame on Dr. Gale. At the time of the March 1, 1993 surgery, Dr. Gale was an employee of Dr. Olson and both Drs. spent a great deal of time with the patient pre-operatively reviewing the possible complications and problems that could occur post-operatively. It would seem that if the surgery on the patient fell below the standard of care then most certainly Dr. Olson would have to share in the repercussions. By the Board not even questioning and/or involving Dr. Olson in this patient’s case in any way, only serves to demonstrate that the Board’s goal here is not to police its own medical discipline nor is it to look out for the best interest of the patient and the public. Rather the Board’s goal is to focus upon causing harm to Dr. Gale with the obvious purpose of running him out of the profession and thereby eliminating any further competition to his professional peers in the Bismarck area (i.e., the Bone & Joint Center and the Board’s President, Dr. Aaron Olson).

Dr. Stone, a Board member, stated at the January 12, 2000 Board hearing in which the Board decided its findings of fact, that no intra-operative x-rays were taken by Dr. Gale and this was the basis for the Board’s findings of fact number one. However, the truth is that intra-operative x-rays were taken and there are reports by the radiologist from Q & R Clinic who read the x-rays. Most importantly, the radiologist reports are in the record. Both page one and two of Dr. Gale’s operative report dated March 1, 1993 is included (Tab 10) and the two radiologist’s reports of x-rays dated March 1, 1993 are also included (Tab 11) in the record. Dr. Gale stated in his March 1, 1993 operative report that x-rays were taken during the surgery to assess the positioning and that, "The intra-operative x-rays revealed that there was good alignment and flush surfaces of the ankle arthrodesis site." Very significantly, the radiology reports both concur that there was proper positioning of the ankle during surgery. Yet, the key words in the Board’s finding of fact number one are that Dr. Gale failed to intra-operatively assess the anatomical position before closure. (Intra-operative refers to what took place during the operation i.e., the intra-operative x-rays are those x-rays taken during the operation). Dr. Stone specifically stated at the January 12, 2000 Board meeting which was taped that "...my recollection is that there is nothing in the record or report that indicated these ways and or means were assessed intra-operatively and that I would think if they had been addressed and documented that this potential complication may have been averted intra-operatively." (Emphasis added) This statement was pointed out in the record by Dr. Gale and Mr. Thune allowed Dr. Gale to submit a letter to the Board after the January 12, 2000 Board hearing to specifically point out to the Board that the radiology reports and Dr. Gale’s operative report were overlooked by Dr. Stone. However, Dr. Stone and the other Board members refused to change their mind about the presence or absence of the x-rays which were taken intra-operatively. Importantly, the radiology report and Dr. Gales’ operative report both are part of the record. How could something so obvious be completely missed by Dr. Stone? Clearly, the other Board members either (1) failed to even review the record or (2) refused to acknowledge the very existence of the reports that are plainly part of the record. As set forth in Kuklock v. N.D. Workers’ Comp. Bureau, supra, the Board must explain inconsistent medical evidence in rendering its opinion and yet, the Board completely failed to comment on evidence that is clearly in the record and which renders its opinion not only inconsistent but totally incorrect.

Furthermore, the first amended complaint fails to raise any issue about intra-operative x-rays not being taken. Since the first amended complaint does not raise any issue about intra-operative x-rays, the Board should not be allowed to raise a new issue after the record and the arguments of the Board and Dr. Gale were closed. Raising a new issue after Dr. Vogler had already completed his opinion did not allow Dr. Gale and his expert (Dr. Vogler) to fairly deal with this new issue. As set forth in Devous and Slagle, raising a new issue without notice to Dr. Gale is unconstitutional and as such, the Board’s decision against Dr. Gale should be reversed.

The Board’s findings of fact number 2 states, "Subsequent to the first operation, the limited subtalar joint motion does not support a calcaneal osteotomy as the proper procedure." This issue is also not in the Board’s first amended complaint. The first amended complaint states, in part, "Dr. Gale performed a calcaneal osteotomy in March, 1994, resulting in residual varus of the foot and pain in the subtalar joint". The Board’s finding of facts states that due to the limited motion the procedure was a bad choice. Yet, in the first amended complaint, the Board only states that the procedure which Dr. Gale performed didn’t work and caused pain. The Board’s findings of fact are outside the first amended complaint and therefore, the Board is again trying to raise a new issue that was not in the first amended complaint after the record was closed. Such conduct denies Dr. Gale and his expert a chance to respond to the new issue. Notably, there is a difference between saying that a procedure was the wrong choice and saying that the procedure did not correct the problem and caused pain. Additionally, both the Board’s findings of fact and the first amended complaint are incorrect according to the record. One only needs to look at the Board’s own expert report (from Dr. McGlamry) which states on page 6 that, "On March 21, 1994, Dr. Gale returned the patient to surgery to correct the varus heel deformity. He performed a calcaneal osteotomy and succeeded in everting the calcaneus to a position of varus or even slight valgus, depending on which of the examiners you chose to accept. But in any event he did correct the heel varus." (Emphasis added) Thus even according to the Board’s own expert, Dr. Gale did correct the problem; and therefore, this part of the Board’s findings of fact is without support in the record and lacks merit and should be reversed. The weight of the evidence supports Dr. Gale’s position that he did nothing wrong, thus the Board’s finding of fact is not supported by a preponderance of the evidence and should be reversed.

As pertains to Dr. Gale’s procedure being the correct choice of procedure, Dr. Vogler (Dr. Gale’s expert) states in his opinion on page 19, #2, "I myself have encountered this complication and problem after performing several hundred of these procedures. Dr. Gale was credentialed and considered qualified by his hospital to perform this procedure as well." Dr. Vogler also provides a reference to authoritative literature (page 19 of his opinion, #4, reference #14) that supports his conclusion that calcaneal osteotomy is an acceptable procedure which is often used and that it can increase motion at the subtalar joint. Dr. Vogler’s opinion establishes the standard of care that should be applied in this particular case. Dr. Gale complied with this standard of care. Accordingly, the Board’s findings of fact number two should be reversed. Again, the preponderance of the evidence does not support the Board’s decision.

As far as the patient’s pain that is mentioned in the first amended complaint, there is no mention of pain anywhere in the record. Why or what caused the patient’s pain is not in the record and there is nothing to support the Board’s allegations that Dr. Gale was responsible for causing her pain. The patient obviously had pain from the original injury and severe arthritis that had developed prior to her ever coming to see Dr. Gale. This fact is in the record and is the reason that the patient was seeking medical attention from Dr. Gale in the first place. If there was pain continuing after the surgery was performed by Dr. Gale for the ankle fusion and the calcaneal osteotomy, the existence of such pain does not mean that Dr. Gale caused the pain. Significantly, the pain that the patient had before she saw Dr. Gale was from the arthritis in the subtalar joint which started after the patient’s original injury occurred which was a few years before she ever saw Dr. Gale. The preponderance of the evidence does not support the Board’s decision.

As relates to the Board’s finding of fact number three, "The follow-up procedure, relative to the varus position was ineffective." [See: Discussion set forth above] The discussion set forth explains that the record clearly provides that both the Board’s expert and Dr. Gale’s expert agree that Dr. Gale’s procedure did in fact correct the problem. The first amended complaint states, in part, "As a result of the procedures, the ankle was in a position of varus, and the tibia was posteriorly displaced on the talus." The Board members at the January 12, 2000 Board meeting all agreed that this position is an acceptable complication. The Board’s expert, Dr. McGlamry, stated in his report, page 6, "It should be acknowledged that even the best of surgeons can err in the positioning fusion of the ankle." Further Dr. Vogler states on page 21 of his opinion, "The complexity of these type of procedures carries the same risks and complications regardless of which experienced surgeon performs the procedures. As noted early, I have encountered these identical problems after several hundred of these procedures. Clearly Dr. Gale is highly trained and experienced, there can be no question about this. His training records demonstrate this." Accordingly, the Board’s findings of fact number three is not supported by a preponderance of the evidence and should be reversed.

Geraldene Parsley:

The Board’s first amended complaint dated April 20, 1998 against Dr. Gale as relates to Geraldene Parsley states that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by:

e. failing to properly treat and care for Geraldene Parsley. Dr. Gale performed a gastrocnemius recession with exploration of the left Achilles tendon on May 2, 1994. The records do not demonstrate this surgery was appropriate and Dr. Gale’s post-operative diagnosis did not match the operative findings.

The Board’s Findings of Fact dated February 2, 2000 as relates to Geraldene Parsley state as follows:

4. Dr. Gale failed to completely and correctly assess pre-operatively findings, both clinical and diagnostic, before the surgical procedure was implemented.

5. Dr. Gale’s pre-operative assessment includes a simultaneous post-operative assessment, both dictated on April 22, 1997, ten days before the operative procedure was completed. This is a departure from the minimal standards of acceptable and prevailing podiatric medical practice.

The Board’s finding of fact number four states, "Dr. Gale failed to completely and correctly assess pre-operative findings, both clinical and diagnostic, before the surgical procedure was implemented." Dr. Vogler on page 9 of his opinion states, "It seems crystal clear from Dr. Gale’s records that surgery was appropriate for this patient, given the circumstances and nature of Ms. Parsley’s condition and complaints and orthopedic findings. Even Dr. Johnson-the complainant- makes this clear in several places in his records over an extended period of time. I wonder if we are all reading the same records?" (Emphasis added) Dr. Vogler, on page 11 of his opinion, states that his conclusion is "The surgery was appropriate and the records do demonstrate this fact." (Emphasis added) Even Dr. McGlamry (the Board’s expert) at page 17 of the Board’s brief states, "The question then must be asked as to whether or not the surgery was needed. And I feel that with 4 years of treatment by Dr. Johnson and with the patient continuing to have painful symptoms and with Dr. Johnson still reporting tightness that the surgery may well have been justified." (Emphasis added) However, after making this statement Dr. McGlamry then went on to say on page 18 of the Board’s brief, "I am persuaded that Dr. Gale took his patient to surgery without adequate documentation in his records of the need for the surgery." Consequently, Dr. Vogler even commented on page 11 of his opinion about Dr. McGlamry’s inconsistent statements wherein Dr. Vogler states, "This is paradoxic and makes no sense since the prolific amount of prior history and record documentation which he must have been provided from Dr. Johnson’s office would have easily made the conclusion for surgery obvious at this point in time." (Emphasis added) The Board’s findings are not supported by a preponderance of the evidence.

The only "clinical" findings that the Board must be referring to are mentioned in the record for patient Geraldene Parsley was the measurement of ankle range of motion. This measurement is in the record as well as being in Dr. Gale’s letter to the Board after the January 12, 2000 Board meeting. The measurement of the range of motion is documented in Dr. Gale’s progress notes as well as the pre-operative History and Physical which Dr. Gale dictated on this patient. This is all in the record. Further the Board members also acknowledged at the January 12, 2000 Board meeting that they had no problem with the procedure being correct for this patient’s situation. It was pointed out by Dr. Vogler, page 9 of his opinion, that the person who sent in the complaint (Philip Johnson, MD) agreed that the surgery was appropriate. Dr. Johnson evaluated this patient and treated her for years before this patient was referred to Dr. Gale by Dr. Fanous to have this procedure performed. Dr. Johnson also saw this patient after she had healed from her surgery performed by Dr. Gale. Dr. Johnson stated in his records which are part of the Board’s record that the patient’s problem was resolved and she no longer had any disability, disability that had been present when Dr. Johnson was treating her prior to her surgery with Dr. Gale. All of this was not only in the record in the first place for the Board to read and review, but it was in Dr. Gale’s letter to the Board after the January 12, 2000 Board meeting which is also part of the record. The Board allegedly read this letter (and the record) prior to the January 27, 2000 Board meeting. Again, the Board’s findings are not supported by a preponderance of the evidence.

The only "diagnostic" procedure that was performed on this patient was an MRI. This was not part of the record. Dr. Stone and Dr. Hofsommer, two members of the Board, took it upon themselves to somehow find the MRI despite the fact that it was not part of the record so they could review it. Furthermore, the MRI was in Bismarck and both Dr. Stone and Dr. Hofsommer reside in Fargo and so they had to make special arrangements to get the MRI since they both knew that the MRI was not in the record. Dr. Hofsommer, at the January 27, 2000 Board meeting, gave an excuse for his conduct essentially stating that he made a mistake and that he knew he shouldn’t have read it. Dr. Stone did not accept any responsibility for his attempt to include his reading of the MRI, when he knew full well that the MRI was clearly not part of the record. There were no other "diagnostic" tests performed and therefore, the Board must be referring to the MRI. Since the MRI is not part of the record, the Board is not allowed to use this information. The briefs from both of the two experts never refer to the MRI and if the Board wanted to add this MRI to the record, then Dr. Gale would have to be given a chance to respond to any such allegations made by the Board about the MRI. At the Board meeting on January 12, 2000, Dr. Hofsommer and Dr. Stone both stated that they took the MRI to radiologists to have them look at the MRI after the record had been closed. At the Board meeting on January 27, 2000, it was acknowledged by the Board’s attorney as well as Dr. Hofsommer, but not Dr. Stone, that the MRI should never have been reviewed by them and that any reference to the MRI by the Board members would have to be removed from the findings of fact. Evidently, Dr. Hofsommer forgot about his earlier statement that he had already made at the January 12, 2000 Board meeting because at January 27, 2000 Board meeting Dr. Hofsommer then stated that he was looking at another patient’s MRI in his office and "suggested" that he thought it was Geraldene Parsley’s MRI and that it was part of the record for her case that he was supposed to be reviewing. At the January 27, 2000 Board meeting, Dr. Stone failed to mention anything at all about why he was reviewing this MRI with a radiologist after the record was closed. Yet, this MRI was the very reason that Dr. Stone and the other Board members agreed that there was a problem with this patient’s case when the Board was drafting their findings of fact on January 12, 2000. For the above reasons, this findings of fact number four is also incorrect and should be deleted. Unfortunately, this is also proof that the Board has tampered with the record and that the Board clearly has not been acting in good faith in its dealings with Dr. Gale. As the court in Slagle held where no notice was given to Slagle on two matters which the Nursing Board considered in arriving at their decision to discipline Slagle, such failure of notice was unconstitutional and required the Board’s decision to be reversed. Such is also the case here since the Board’s conduct in considering evidence not in the record and basing a decision on such evidence without giving Dr. Gale an opportunity to produce evidence on such evidence is unconstitutional and should be reversed.

The Board’s finding of fact number five is that, "Dr. Gale’s pre-operative assessment includes a simultaneous post-operative assessment, both dictated on April 22, 1997, ten days before the operative procedure was completed. This is a departure from the minimal standards of acceptable and prevailing podiatric medical practice." This finding demonstrates that the Board has not made a good faith attempt to review and understand the record. The Board’s finding first of all contains a typographical error since all the events took place in 1994, and not 1997. The note in Dr. Gale’s file regarding this patient is dated April 22, 1994 and such note is attached (Tab 12. ) Accordingly, this is a patient record which Dr. Gale dictated on April 22, 1994 after a pre-operative office visit with the patient and the format of this dictation is standard in the profession. It is standard procedure at a pre-operative office visit dictation to state that the post-operative diagnosis will be the same as the pre-operative diagnosis. Coincidentally, this is the very same format that Dr. Aaron Olson used when Dr. Gale was employed by Dr. Olson. One can see that Dr. Olson used the same format when he had a pre-operative office visit with a patient (Shirley Sailer) prior to an operation (Tab 13) wherein Dr. Olson states the post-operative diagnosis is the same as his pre-operative diagnosis. [Note: Tab 13 for Shirley Sailer is part of the record, but it is found in the record as relates to Shirley Sailer’s patient records.] Similar pre-operative office visit dictations for the other patients will be found in the record also. The operative report for Geraldene Parsley was not dictated on April 22, 1994, rather it was dictated on May 2, 1994 (Tab 14). May 2, 1994 is the same day that Geraldene Parsley had her surgery performed by Dr. Gale. Importantly, the operative report is prepared by the hospital (here Medcenter One) and not by Dr. Gale or his staff. The operative report is dated May 2, 1994 and one can see at the end of the dictation that the dictation was performed on May 2, 1994 and the date it was transcribed was May 8, 1994. The Board has no factual basis in the record or from the two experts that establishes that a pre-operative assessment cannot refer to a post-operative assessment. As set forth above, this is standard procedure. Even the Board’s own President (Dr. Olson) utilizes this exact same procedure. Accordingly, the Board’s finding of fact number five is not supported by a preponderance of the evidence and should be reversed.

Furthermore, there is nothing in the first amended complaint that raises any issue about a pre-operative report being dictated ten days prior to the surgery and no reference to any post-operative diagnosis as being an issue of something that Dr. Gale should not have done. Additionally, there is nothing in the Board’s brief or its expert’s opinion that refers to Dr. Gale’s pre-operative office visit and dictation dated April 22, 1994 as somehow being improper. On April 22, 1994, the patient was seen by Dr. Gale before the surgery to go over the procedure and sign the consent forms at Dr. Gale’s clinic. In most instances, the pre and post operative assessments are known and are the same. If the assessment changes at the time of surgery, then the assessment is changed on the official operative report that is dictated after the surgery. There is no "rule" that states a planned surgery is only what has to be performed or the only operation that will be performed. In fact, just the opposite is true. There is a reference to a document in the record that states that if it’s in the best interest of the patient, the surgical procedure can and should be modified in whatever manner is necessary. This is part of a series of documents established by the American College of Foot & Ankle Surgeons (ACFAS) which is the authority on foot and ankle surgery in the United States. Dr. Gale is a Fellow of the ACFAS. The other Board members who are podiatrists understand the meaning of the pre-operative office visit record dated April 22, 1994 and they should have clarified this issue for Dr. Moen, but they didn’t bother to do so. It was Dr. Moen who brought up this issue at the January 12, 2000 Board meeting. Dr. Moen is a family practice medical doctor who does not perform surgery and therefore, Dr. Moen was more than likely confused about the purpose of this pre-operative office visit. Likewise the April 22, 1994 dictation does not state anywhere in it that surgery was performed on April 22, 1994. There are documents in the record other than just the operative report that support the fact that the surgery was performed on May 2, 1994, not April 22, 1994. Again, this issue has to do with medical records and such issue is not part of the complaint against Dr. Gale. Thus this issue should not be considered since the Board once again is attempting to raise a new issue that is outside the scope of the first amended complaint; and accordingly, in direct conflict with Dr. Gale’s right to due process, similar in nature to the Devous and Slagle cases which held that such conduct was a violation of their constitutional rights.

The record in the Parsley case clearly shows that this patient had a tight Achilles tendon. It also shows that the Board and the doctor who submitted the complaint agree that the surgery was appropriate and that the procedure healed well. Further the patient’s problem, for which she went to see both Drs. Johnson and Fanous and then Dr. Gale, was completely resolved after her surgery by Dr. Gale. There was never any complaint from the patient, and the doctor who submitted the complaint against Dr. Gale was simply confused by the wording in Dr. Gale’s medical records. The Board members all agreed at the January 12, 2000 Board meeting that it did not have a problem with the procedure and that the patient (Geraldene Parsley) did heal well; and furthermore, this is clearly in the records of the doctor who sent in the complaint against Dr. Gale. Dr. Gale’s medical records are not an issue with this patient. Additionally, the first amended complaint for this patient states that the Board is claiming that Dr. Gale violated sections g, k and u. Medical record violations are contained in subsection "n" and were not an issue with this patient and most importantly, subsection "n" was never an issue in the first amended complaint. If Dr. Gale’s records had been made an issue, such records would have been considered by both of the expert witnesses. Medical records were never an issue in the first amended complaint. Medical records cannot be grounds for disciplinary action against Dr. Gale. There is no argument by the Board or it’s expert but that the patient needed the surgery and that she healed well without any problems. The fact is that once again the Board is attempting to raise a new issue after the record is closed. The Board has simply refused to look at the record and has refused to recognize that the record clearly and simply explains that Dr. Gale did nothing wrong with this patient from beginning to end. The Board’s findings of fact against Dr. Gale is not supported by a preponderance of the evidence and should be reversed. The Board’s raising a new issue is similar to Devous and Slagle and is unconstitutional conduct requiring reversal of the Board’s decision.

Margie Pulkrabek:

The Board’s first amended complaint dated April 20, 1998 against Dr. Gale as relates to Margie Pulkrabek states that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by:

d. failing to properly treat and care for Margie A. Pulkrabek. Dr. Gale performed a tarsal tunnel release with plantar fascia release on the right foot in December 1994. Ms. Pulkrabek was left with persisting numbness and pain in the right foot following the surgery. A tarsal tunnel release was not indicated. The procedure was not properly performed in that the medial calcaneal nerve was cut.

The Board’s Findings of Fact dated February 2, 2000 as relates to Margie Pulkrabek states as follows:

6. Dr. Gale failed to provide the patient with adequate information as to the risks (i.e. numbness, etc.), benefits and alternatives, prior to performing the surgical procedures. There was a lack of adequate informed consent obtained in this case.

7. The surgery was performed prematurely, given the absence of changes in the nerve conduction study.

8. Post-operatively, Dr. Gale failed to disclose the severing of the medical calcaneal nerve, which generated the resulting numbness experienced by the patient.

Pertaining to findings of fact number six stating that Dr. Gale failed to provide the patient with adequate informed consent and adequate information as to the risks, the first amended complaint does not make informed consent or adequate information as to the risks an issue; thus the Board has again created a new issue after the record has been closed and Dr. Gale has not been given an opportunity to address this new issue. Raising a new issue after the record is closed is a denial of due process which is similar to Devous and Slagle and accordingly, findings of fact number six is unconstitutional and should be reversed.

Even though the Board improperly raised a new issue after the record was closed, there are several places in the record that demonstrates that informed consent was given to the patient. The informed consent which explains the procedure most clearly, as well as gives the patient a list of possible complications, is the consent form from Dr. Gale’s clinic which was signed by the patient on December 8, 1994 (Tab 15). This informed consent states:

1. I hereby request Dr. Gale to perform upon Margie Pulkrabek the following operation or procedure 1. RELEASE OF LIGAMENT AT BOTTOM OF FOOT (PLANTAR FASCIA) 2. RELEASE OF ENTRAPPED NERVE IN ANKLE AND ARCH (TIBIAL NERVE) and if any unforeseen condition arises in the course of the operation calling in his judgment for procedures in addition to and/or different from those now contemplated, I further request him to do whatever he deems advisable.

2. The nature and purpose of the operation, possible alternative methods of treatment, the risks involved, and the possibility of complications have been explained to my satisfaction (chance of thick or painful scar, prolonged pain, prolonged swelling, post-operative infection, over or under correction, or a chance of further surgery may be necessary).

3. I have also been informed that there are other risks involved related to the performance of any surgical procedure. I realize that the practice of medicine and surgery is not an exact science and I acknowledge that no guarantees have been made to me as far as the outcome of the operation or procedure.

4. I, Margie Pulkrabek, have read and understand this document and all my questions regarding my procedure/surgery have been answered to my satisfaction.

5. Dated this 8th day of December 1994.

This consent was witnessed by Dr. Gale’s nurse. Further this consent form was not developed by Dr. Gale. This is a standard consent form that is used by surgeons in many different areas. Plus the hospital has it’s own consent form as well. Dr. Gale also notes in his dictation on December 8, 1994 (Tab 16), the same date the patient signed the above described consent, "The patient understands there have been no guarantees given or implied. The patient also understands that there is a chance of thick or painful scar, recurrent heel pain, recurrent ankle pain or arch pain. The patient understands there is a chance of over or under correction, and further surgery, post-operative infection, or anesthetic reaction." In Dr. Gale’s Clinical History, page two, last paragraph, which he dictated on December 14, 1994 (Tab 17) states the above, along with " . . . recurrence of either the heel pain or of neurologic symptoms or both". The patient went to Dr. Gale with the understanding that Dr. Gale would be performing the surgery for her that she needed, and she wanted to have this surgery performed.

The signed consent above (Tab 15, item 2) shows that the patient was offered conservative care and given information about the possible risks involved, still the patient wanted Dr. Gale to go forward with the surgery. There are also hospital consent forms signed by the patient which are in the record. It is impossible to consider every possible risk or complication, however, what is important and reasonable is that Dr. Gale did offer conservative care and Dr. Gale did give the patient information about the risks involved in the operation; he also notified the patient that he could not give her any guarantees as far as the outcome of the operation. The Board’s findings of fact number six is not supported by a preponderance of the evidence and should be reversed.

The Board’s finding of fact number seven states, "The surgery was performed prematurely, given the absence of changes in the nerve conduction study." It is important to point out for the Court that Dr. Aaron Olson saw this patient on February 23, 1988 (Tab 18) for the same problems for which she came to Dr. Gale for help and Dr. Olson stated, "Quite honestly it is difficult to assess what this lady has. She just has some capsullitis or tendonitis at the ankle. I cannot rule out that she may not have some osteochondritis, desiccants of the talar dome. She may have an arthritis symptomatology or just wear and tear." This clearly demonstrates that the patient was having symptoms/pain for six years prior to even seeing Dr. Gale, however, Dr. Olson was not able to figure out what was wrong with her. How long must a patient suffer before its okay to perform surgery?

Dr. Vogler made it very clear in his expert opinion, page 4, that in several instances an abnormal nerve conduction is not necessary prior to performing surgery on a patient with this condition. The Board’s own expert (Dr. McGlamry) agreed with Dr. Vogler’s opinion as well. This was also well documented by Dr. Vogler in his opinion, pages 4 though 8. The surgery was further indicated since extensive non-surgical care (conservative care) had already been performed by Dr. Fanous who referred the patient to Dr. Gale to perform the necessary surgery. Everything that is mentioned in regard to conservative care that can or should be performed was already performed by Dr. Fanous. The Board implies that Dr. Gale must perform conservative care before he is "allowed" to perform surgery on a patient. As established by the American College of Foot and Ankle Surgeons (ACFAS) (Tab 19), "If conservative therapy is impractical, fails to reduce the patient’s symptomatolgy to a tolerable level, or is inadequate to prevent recurrent injuries, surgical intervention is the treatment of choice when the patient is informed of the etiology, course, and prognosis of the deformity, as well as the risks and ramifications of surgery." Such care as established by ACFAS (Tab 19) is in the record. The American College of Foot & Ankle Surgeons establishes the standard of care in the podiatry profession. The reason the American College of Foot & Ankle Surgeons establishes the standard of care is that there are many possible instances where conservative care is not in the best interest of the patient. For example, if the patient has had severe pain for a year and has been treated by one doctor already and the patient both needs and wants to have surgery, it should be done. To not perform surgery in this instance, would be potentially a breach of the standard of care. That is precisely why Dr. Fanous, who does not perform this type of surgery, referred the patient to Dr. Gale who Dr. Fanous knew could do the surgery. It is not always true then that surgery is an option only after a required amount of non-surgical care. In this case, the nurse called Dr. Gale’s patient on November 21, 1994 (Tab 20) and the nurse told the patient that Dr. Gale wanted to do one more injection. However, the patient stated, "...they cause cancer & all other kinds of other horrible things" and the patient told the nurse that she wanted the surgery; thus the nurse noted "Pt wants surgery". The Board never produced any documentation or expert opinion whatsoever that indicates that a change in a nerve conduction study is a requirement for surgery in this type of case or that even a nerve conduction study must be performed in a patient with this type of problem. In fact, in the evaluation by neurologist, Dr. James B. Ragland (Tab 21) who saw Margie Pulkrabek at Dr. Gale’s request, Dr. Ragland indicated that the patient was having pain and that there were nerve changes on the EMG that he performed. This, too, is part of the record as Dr. Raglund’s evaluation is extensively discussed by Dr. Vogler in Dr. Vogler’s expert opinion report. There is no place in the authoritative literature where it can be found that surgery should not be performed if the nerve conduction study is normal. In fact, the authoritative literature is very specific about this and as stated in the record (Dr. Vogler’s  opinion, page 6, last two sentences) there is a direct quote from authoritative literature and from the Board’s own expert’s (Dr. McGlamry’s) text that, "In fact the Board’s expert Dr. McGlamry states in his book on page 1114 that, ‘The diagnosis of tarsal tunnel syndrome is based on historical interview and physical findings. The distribution of sensorimotor alteration is the key to accurate diagnosis.’" Dr. McGlamry goes on to say " . . . one should not discount the clinical diagnosis of tarsal tunnel syndrome in light of negative electrodiagnostic findings." In layman’s terms, this means that tarsal tunnel syndrome can be diagnosed by the amount and location of the pain and often the nerve conduction test is normal. In this case, the EMG was abnormal and indicates tarsal tunnel syndrome. Notably, the patient was having severe pain and refused further conservative care and insisted on and needed to have surgery for her problem. Accordingly, the Board’s findings of fact number seven is not supported by a preponderance of the evidence and should be reversed.

The Board in its findings of fact number eight states, "Post-operatively, Dr. Gale failed to disclose the severing of the medical [sic] calcaneal nerve, which generated the resulting numbness experienced by the patient." [Note: The proper name for the nerve is the "medial", not "medical"]. This issue was never raised in the first amended complaint. The first amended complaint states, "The procedure was not properly performed¼" there is nothing about whether Dr. Gale "failed to disclose". Not only has the Board raised a new issue again, after the record was closed, which is unconstitutional conduct by the Board, but the record does not prove that Dr. Gale severed any nerves. Accordingly, there is no factual basis in the record for the Board’s finding of fact that Dr. Gale severed the medial calcaneal nerve and thus the Board’s findings to the contrary is not supported by a preponderance of the evidence. When Ms. Pulkrabek allegedly did develop some problems, she did not contact Dr. Gale so there is no way he could have helped her. All we have that even "suggests" that there may have been a problem with this nerve comes from one single office visit with Dr. Bopp (Tab 22) on December 26, 1995 which states, "What I think is most consistent with her exam is calcaneal branch of the tibial nerve was cut at surgery. She did not have this numbness before the surgery and she definitely has it now. It is a known complication of plantar fascial release and in my opinion, this calcaneal branch of the nerve was in fact cut at the time of surgery. This is the cause of her persistent numbness and tingling." Clearly, there are ways that a diagnosis could have been made to see if in fact this nerve really was "severed"; however, the tests to make this diagnosis weren’t performed. Furthermore, there was never any treatment for this patient for a severed nerve, so it has to be assumed that there never really was a severed nerve. Dr. Vogler in his expert opinion describes several ways that a severed nerve can be successfully treated if in fact there actually was a severed nerve. Likewise there sometimes is simply a medication or an injection that can successfully resolve the type of numbness and pain which can occur after this type of procedure. Since nothing was ever done to determine for sure what the problem actually was and since the patient didn’t want any further treatment, it is impossible to state then that Dr. Gale severed this nerve and further lacking any evidence that Dr. Gale did there is nothing then that warrants a complaint or disciplinary action. Additionally, it is in the record that numbness is sometimes the intended result to relieve severe pain some patients have with this condition. In fact, this nerve is sometimes intentionally cut in some particular cases in order to relieve the pain. For a proper diagnosis, a neurologist should have been consulted to identify if this was indeed the problem or to treat the patient; but evidently, Dr. Bopp and/or the patient didn’t feel it was necessary. The surgical consent form the patient signed with Dr. Gale covers this as a possible complication. Such consent specifically states "prolonged pain" as a possible complication. The patient was doing very well at the time that she decided not to come back to see Dr. Gale any longer; importantly, she only had a little numbness and no pain at all when Dr. Gale last saw her. There is no way that Dr. Gale could have foreseen that one year later she was going to have some problems, if indeed she did have problems and/or the nature of the alleged problems; and there is no way that Dr. Gale could force a patient to come back to him for more treatment since that is the patient’s prerogative. The record does not contain a preponderance of the evidence to support the Board’s decision and accordingly the Board’s decision should be reversed.

Dr. Vogler, at page 8 of his expert opinion concerning this patient, states:

It is clear that the allegations contained in the Board’s complaint failed to consider all information available and are simply wrong. Dr. Gale factually did properly treat and diagnose Ms. Pulkrabek with more than sufficient justification to arrive at a working diagnosis of tarsal tunnel syndrome and chronic plantar fasciitis. Review of the operation report clearly defines a conventional and thorough decompression operation. "Persisting numbness" along the medial calcancal nerve branch as the Board alleges, is a common occurrence after this operation and not entirely undesirable and often intentional by many well known surgeons in this country and abroad.

Additionally, the Board has a duty to explain inconsistencies, see Kuklock v. N.D. Workers’ Comp. Bureau, supra, and most certainly the Board did not try to explain Dr. Vogler’s clear opinion that Dr. Gale did nothing wrong. The Board did not even attempt to set forth a basis in the record to support their findings. The Board’s findings of fact and conclusion as relates to Ms. Pulkrabek are wrong and such findings of fact and conclusion are not supported by a preponderance of the evidence and should be reversed.

Shirley Sailer:

The Board’s first amended complaint dated April 20, 1998 against Dr. Gale as relates to Shirley Sailer states that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by:

h. failing to properly treat and care for Shirley Sailer. Dr. Gale attempted to repair the hallux varus (iatrogenic) of the right foot following a bunion correction in 1990 by another podiatrist. Dr. Gale’s June 1996 surgery on the right foot involved soft tissue balance and osteotomy of the first metatarsal phalangeal joint. The pre-operation varus of the hallux was approximately 15 degrees; the final position of approximately 20 degree varus with elevation of the first metatarsal head. Dr. Gale failed to recognize shifting of osteotomy from the earlier x-rays. There was also further loosening of the screw and proximal migration of the capital fragment.

The Board’s Findings of Fact dated February 2, 2000 as relates to Shirley Sailer states as follows:

9. In an attempt to surgically correct a hallux varus of the patient’s right foot, Dr. Gale failed to intra-operatively recognize that the osteotomy was not correcting the problem. The intra-operative reporting contains no acknowledgment of the procedural problems.

10. Post-operatively, Dr. Gale continued his failure to recognize that the hallux varus had not been corrected, in spite of the fact that his post-operative x-ray indicated the initial surgery was inadequate to correct that problem.

Hallux varus is a problem that occurs when a bunion is surgically over corrected. It results in the big toe pointing towards the opposite foot. The Board’s brief, page 12, states that this patient was operated on by Dr. Aaron Olson in 1990 for bunion surgery and that her toe had since gone into over correction. Dr. Gale first saw Ms. Sailer on December 5, 1995 and Dr. Gale’s x-rays on December 5, 1995 demonstrated that Dr. Olson’s surgery had gotten the head of the metatarsal too far laterally resulting in an over correction of the hallux. Therefore, on June 10, 1996, Dr. Gale attempted to surgically correct the hallux varus.

The Board’s findings of fact number nine referring to the intra-operative report is again raising a new issue that is not contained in the first amended complaint and such conduct by the Board is unconstitutional and the Board’s decision should be reversed on this basis alone. However, based on the record, the Board’s decision is in error anyway. First of all, and most importantly, the intra-operative report contains no acknowledgment of any procedural problems since the osteotomy performed by Dr. Gale did correct the problem. Unfortunately, the pre-operative problem reoccurred sometime after Dr. Gale’s successful operation. Additionally, the Board was given information explaining that this is a very difficult problem to correct. The first amended complaint never mentions anything about the intra-operative report or any problem associated with the intra-operative report. An intra-operative report again pertains to medical records. Any medical records complaint involves section 43-05-16(1)(n), N.D.C.C. The first amended complaint against Dr. Gale does not include any charge or allegation that Dr. Gale has violated subsection "n" and therefore, the Board’s findings of fact relating to medical records (subsection "n") is once again unconstitutionally raising a new issue after the record is closed and is depriving Dr. Gale of due process as relates to this new issue.

In Dr. Vogler’s expert opinion, page 16, he references authoritative literature which explained that over 50% of the attempts at correction of this difficult problem are unsuccessful. Does this mean that 50% of the doctors who were unable to correct this problem for their patients should all be disciplined? Dr. Vogler and Dr. McGlamry both agreed that this type of problem is extremely difficult to correct. Dr. Gale has advanced training in the foot and ankle. Some patients come to him from all over North Dakota and the surrounding states for him to treat them. Most of these patients have been to several doctors in an attempt to have their problems corrected, but no one can or is willing to try to help them. Dr. Gale tells all of his patients in this type of situation that he will do what he can for them but that in this type of procedure as in most all procedures there are no guarantees given as to the final results. Hence this is precisely what is stated in the consent form that this patient (Sailer) signed. The consent in this case that the patient signed (Tab 23) states that there is a chance of "¼ over or under correction." This patient signed the very same type of consent form that patient, Margie Pulkrabek, signed; the same form that all five patients signed. This is the very purpose for providing informed consent by patients. It is common knowledge to patients and doctors that not all surgery will turn out one hundred percent perfect thus the reason/need for consent forms. Consequently, the patient knows full well that there are certain risks involved in any type of surgery.

There is nothing in the original complaint from the patient that states that Dr. Gale failed to recognize anything intra-operatively. Significant here, is the fact that this is the only patient out of the five complaints against Dr. Gale who actually sent in a complaint. As Dr. Vogler points out in his opinion, page 15, Ms. Sailer’s complaints were (1) that Dr. Gale took no x-ray, (2) her orthotics were unsatisfactory and (3) her big toe was "all screwed up." Importantly, the only reason that she sent in the complaint was because at the time she sent in the complaint she was again seeing Dr. Olson and Dr. Olson encouraged her to file a complaint against Dr. Gale. Reference to Dr. Olson’s file concerning Ms Sailer (Tab 24) states, "She tells me quite frankly she feels she has been injured and wants to know what can be done to prevent other people from being injured. Without comment, I’ve told her the Board of examiners handles complaints or the Ethics and Grievance Committee of the State Association is the appropriate avenue. She indicates she has already gotten names and wanted to know if I had other suggestions." On page 13 of the Board’s brief the Board states, "Patient eventually left the care of Dr. Gale and returned to Dr. Olson who diagnosed an elevatus of the right first metatarsal head, aseptic necrosis of the first metatarsal head, and metatarsalgia of the second and third metarsals. [The x-rays appear to contradict a diagnosis of both the metatarsal elevatus and of aspectic necrosis.]" Notably, the Board even notes that Dr. Olson’s diagnosis is incorrect; yet, the Board has taken no disciplinary action against Dr. Olson for his errors.

The patient stated in her original complaint that Dr. Gale failed to take any x-rays. The patient is mistaken. Dr. Gale took several x-rays to assess the patient’s healing. Even the Board’s findings of fact number ten states that Dr. Gale took x-rays and thus the patient was mistaken about this complaint.

Dr. Gale also explained to the patient on July 2, 1996 that the surgery he performed did not completely correct the Hallux Varus problem (Tab 25). However, the patient’s problem was much improved when she left Dr. Gale’s care compared to when she first came to Dr. Gale. The first amended complaint states, "elevation of the first metatarsal head". Still the Board’s own expert (Dr. McGlamry) disagrees with this at page 14 of the Board’s brief whereby Dr. McGlamry states, "Please note that Dr. Olson later refers to this as elevatus of the first metatarsal head, which definitely is not the case." Accordingly, the Board’s own expert disagrees with this portion of the first amended complaint. Thus the Board’s finding of fact number nine is not supported by a preponderance of the evidence and should also be reversed.

The Board’s finding of fact number ten states, "Post-operatively, Dr. Gale continued his failure to recognize that the hallux varus had not been corrected, in spite of the fact that his post-operative x-ray indicated the initial surgery was inadequate to correct that problem." Dr. Aaron Olson originally over corrected the deformity (bunion) during the first surgery for this patient. If anyone is to blame for the patient’s problems in this case, it is clearly Dr. Olson and not Dr. Gale. Dr. Gale was attempting to correct Dr. Olson’s mistake. Not always having perfect surgery results is not a basis for Dr. Gale to be disciplined. There was informed consent signed by the patient and further all indications are that this is a very difficult surgery for the very best of surgeons to perform (i.e., with 100% correction). With this, even the Board agrees. Dr. Gale’s own records state that the surgery did not completely correct the problem (Tab 25 and Tab 26). The Board has refused to acknowledge that (1) Dr. Gale did point this out to the patient and (2) Dr. Gale made certain that he documented that he did not completely correct the Hallux Varus deformity. Thus the Board’s findings of fact number ten is not only not true but is not supported by a preponderance of the evidence. The record is clear that Dr. Gale acknowledged that the hallux varus had not been one hundred per cent corrected and therefore, this findings of fact number ten should be reversed.

Gladys Wright:

The Board’s first amended complaint dated April 20, 1998 against Dr. Gale as relates to Gladys Wright states that Dr. Gale violated the provisions of section 43-05-16(1)(g), (k) and (u), N.D.C.C. by:

g. failing to properly treat and care for Gladys Wright. Dr. Gale performed a total joint implant of the right first metatarsal phalangeal joint in July 1996. The phalangeal component of the implant was in a plantarflexed position after surgery and there was loosening of the distal component. Joint congruity also failed to be kept after surgery. Dr. Gale failed to diagnose loosening of the implant.

The Board’s Findings of Fact dated February 2, 2000 as relates to Gladys Wright states as follows:

11. The total joint implant arthroplasty performed by Dr. Gale on this patient’s right first metatarsal phalangeal joint was procedurally done incorrectly. While this is a difficult procedure, the failure of Dr. Gale to recognize the improper placement of the implant, intra-operatively, is a departure from the minimal standard of acceptable and prevailing podiatric medical practice.

12. Of even greater concern is Dr. Gale’s failure, post-operatively, to recognize and identify the incorrect positioning of this implant in the medical records, prior to this patient leaving Dr. Gale’s care.

Dr. Vogler in his expert opinion page 13 states, "Interestingly, this particularly case represents a surgical failure of Dr. Olson, who performed the original bunionectomy some 8 years earlier on Ms. Wright. The patient admitted to pain and swelling "ever since the operation." Thus Dr. Olson never resolved her problem. Dr. Olson is the President of the Board that is involved in this case." (emphasis added) The records of this patient reveals that the joint replacement by Dr. Gale was not done incorrectly. There was good alignment of the joint during the surgery performed by Dr. Gale. Furthermore, there were no problems during the surgery. The x-rays taken by Dr. Gale after the surgery and subsequently, do reveal that one part of the implant is slightly tilted; however, this is not near the joint where the alignment is excellent. There is a slight tilt of part of the implant, however, this is not even where the patient was having her discomfort. The first amended complaint states in part, "The phalangeal component of the implant was in a plantarflexed position after the surgery ¼" Dr. Gale agrees that the implant was slightly plantarflexed (angled downward), but this is not a reason for the patient to be having pain; most importantly, this was not even the area where she was having a problem. Dr. Gale did also recognize that the implant was slightly plantarflexed and documented this in the patient’s chart. Dr. Gale explained to the Board that he did not believe that the implant being slightly plantarflexed was of any consequence and was not causing the pain and/or was not even in the area where the pain was and as such, was a very minor point. Again this was not where the patient was having any pain (Tab 27) and this is what Dr. Gale stated in his x-ray report. Since this was not the area where the patient was having problems and since Dr. Gale felt that the implant being plantarflexed was not significant, Dr. Gale did not then report to the patient about the implant being slightly plantarflexed.

There is no issue in the first amended complaint that Dr. Gale "intra-operatively" failed to recognize an improper placement of the implant and so again, the Board is unconstitutionally now raising a new issue after the record has been closed. The Board’s raising of a new issue after the record has been closed denies Dr. Gale due process of law and therefore, the Board’s finding of fact number eleven should be reversed.

The Board’s findings of fact number twelve states: "Of even greater concern is Dr. Gale’s failure, post-operatively, to recognize and identify the incorrect positioning of this implant in the medical records." This finding by the Board is incorrect and contrary to the evidence in the record. Prior to this patient leaving Dr. Gale’s care, Dr. Gale did recognize and document in the chart that the phalangeal component was slightly plantarflexed. (Tab 27 and Tab 28). In addition, this finding of fact refers to the medical records and there was no issue raised in the first amended complaint about violating subsection "n" relating to improper management of medical records. Again, to this extent the Board is unconstitutionally trying to impose punishment on Dr. Gale for a new issue that he was never given notice of and had no opportunity to defend against; thus this finding of fact number 12 should be reversed. Additionally, the Board’s findings are not supported by a preponderance of the evidence and should be reversed.

In Dr. Vogler’s expert opinion, page 13, he refers to this patient’s own evaluation of her problem when she went for a second opinion to Dr. Hart (an orthopedic surgeon with 6 months of residency training and the person who sent in the complaint against Dr. Gale). Technically, there was no actual complaint ever filed by Dr. Hart; rather there was a cover letter from the office manager of the Bone & Joint Clinic with a copy of the records from this patient. The cover letter from the Bone & Joint Center’s office manager simply said they were concerned about standard of care issues and wanted the Board to review the records. Essentially, what the Bone & Joint Center doctors were saying was to look at these records and see if the Board can’t find something wrong with them. Ironically, even though the Bone & Joint’s complaint involved a question about the standard of care, the Board has completely ignored discussing what the standard of care was with this patient or any of the five complaints. The Board’s failure to address the standard of care or the minimum standard of care in this case is sufficient basis alone for reversal.

Dr. Hart had Gladys Wright complete a patient questionnaire the first time she went to see him on January 20, 1997 (Tab 29). In this questionnaire, which is part of the record, Gladys Wright indicates on question 3 "there is no limitation of any recreational or daily activity", on question 4 "I am able to walk more than 6 blocks", on question 5 "I have some difficulty with uneven ground, stairs inclines or ladders (vs. severe difficulty)", on question 6 "I look normal when I walk", on question 7 "I am mildly displeased with the appearance of my feet and ankles", on question 8 "I usually wear conventional comfort shoewear without an orthotic or insert", on question 9 "the foot and ankle problem interferes mildly with (my) lifestyle and ability to do what (I) want to do". Clearly, these are not statements that a patient would make if she was having a serious foot problem. Hence the patient was actually doing fairly well when she left Dr. Gale and had she continued to have Dr. Gale treat her she more than likely would have continued to improve even more. She was placed in a temporary strapping the last time she saw Dr. Gale and she was very comfortable. (This strapping was a simple pad that was applied to the bottom of the patient’s foot to take some of the pressure off of the "ball of her foot" and this provided her with a lot of relief). This pad was no where near the area of the implant, where it was slightly tilted. Because she had relief from the temporary padding, she more than likely only needed to be fitted with a custom arch support for continued relief. The last note in Dr. Gale’s chart (Tab 30 ) by one of Dr. Gale’s staff for the patient on November 25, 1996 states that the "cut out pad has helped a lot." Dr. Gale sent a request to the patient’s insurance company to receive pre-approval for custom arch supports (orthotics). In return, a letter was sent to Dr. Gale dated December 10, 1996 indicating that she was approved for the orthotics. This letter is also in the record. Accordingly, the tilt in the implant did not effect the joint alignment whatsoever. In Dr. Hart’s chart for this patient, Dr. Hart’s initial evaluation (January 20, 1997) (Tab 31) also indicates that the patient is doing well and not having much of a problem with her foot. The "Foot and Ankle Clinical Rating System" (examination) rates the patient’s range of motion at this joint as "moderate restriction" (30-74 degrees) which is indeed much better than what it was prior to the surgery when the patient had essentially no motion at all. Notably, her initial surgery (which left her with essentially no motion at all) had been performed by the Board’s President, Dr. Aaron Olson. Following Dr. Gale’s surgery, the joint stability of the patient was rated by Dr. Hart as "stable" and most importantly, the evaluation was that the alignment received the highest rating possible of "Good, hallux aligned". Later, on April 4, 1997 (Tab 32) Dr. Hart decided to change his mind and decided that the patient is having more problems than he originally stated. In this April 4, 1997 note, Dr. Hart states that he believes that Ms. Wright has a loose prosthesis. However, Dr. Vogler, page 13 of his opinion, clearly disagrees with Dr. Hart’s evaluation that there ever was a loose prosthesis. Dr. Hart then went on to perform surgery on this patient to remove the joint replacement which Dr. Gale had put into her foot and Dr. Hart’s surgery then fused the joint to make it permanently stiff. Significantly, in the Board’s brief, page 12, their own expert (Dr. McGlamry) sharply criticizes Dr. Hart for the poor results Dr. Hart achieved with the surgery that he performed on this patient even stating, "...due to Dr. Hart’s lack of either competence or judgment." Accordingly, Dr. Olson performed the original surgery on this patient that was unsuccessful and then Dr. Hart performed the third surgery on her which the Board’s own expert states demonstrated a "lack of competence or judgment". Yet, Dr. Hart says the post-operative x-rays from the surgery that he performed look "excellent"; however, the Board’s own expert clearly disagrees. Dr. McGlamry, page 10 of the Board’s brief, states that the plate and all the screws that Dr. Hart put in are loose and the positioning of the joint is wrong. Still, and very conspicuously, Dr. Gale is the only person who is being disciplined and allegedly is at fault despite the fact that the patient was doing fairly well at the time that the patient decided on her own to leave Dr. Gale’s care. Not so coincidentally, neither the Board’s President (Dr. Aaron Olson) nor the Bone & Joint Center doctor alleging complaints against Dr. Gale (Dr. Hart ) have ever been subjected to any disciplinary review and/or action resulting from their incompetence or lack of judgment. The Board’s decision is not supported by a preponderance of the evidence and should be reversed.

Once again, in the Sailer case, the patient signed the same consent form as did all of the other patients (Tab 33). The Board agrees that this is a difficult surgery and Dr. Gale believes that the surgery really went well although he acknowledges (as Dr. Hofsommer stated at one of the Board meetings) that "the alignment of the implant was less than perfect". Does this mean that all of Dr. Gale’s surgeries must be one hundred percent perfect or he (and he alone) shall be subject to skewed allegations and disciplinary action by this Board?

Lastly, it is very important to mention again the informed consent signed by all five of these patients. How is it that informed consent when obtained by Dr. Gale is alleged to be inadequate/ineffective and thereby only works against Dr. Gale rather than in his defense? The record clearly shows that the patient was told (Tab 34 and Tab 35) that she may need "further surgery including a different joint replacement or a joint fusion" (which is what Dr. Hart unsuccessfully attempted to do) as well as other possible complications. The Board’s decision to impose discipline on Dr. Gale for this operation (and none whatsoever against Dr. Olson and/or Dr. Hart) lacks merit and is not supported by a preponderance of the evidence in the record. Accordingly, the Board’s decision is arbitrary, capricious and bias should be reversed.

Out of the five patients, three were treated by Dr. Gale after the patient was treated unsuccessfully elsewhere and two of these three were patients of Dr. Olson. Dr. Gale was treating other doctors complications. The remaining two patients had excellent results not only according to Dr. Gale’s records but also according to the experts opinions and the Board’s statements as well. How can a doctor be disciplined for trying to correct someone else’s mistakes or for having excellent results? The simple fact is that Dr. Gale’s extensive training is what brings patients from hours away to see him and this extensive training is why the local competitors have attacked him.

Conclusion

The above analyses of the facts and law demonstrates that the Board’s decision against Dr. Gale should be reversed and the five complaints should be dismissed. The Board failed to provide Dr. Gale his constitutional guarantees to due process of law and notice of the charges against him so that he could adequately prepare a defense. Dr. Gale has an inalienable right, the most precious of all rights, to earn a living. As the Devous court held "...The right to earn a living is among the greatest of human rights and, when lawfully pursued, cannot be denied...in any honest employment he may choose, subject only to such reasonable regulations as are necessary for the public good ...". Slagle further provides that where a Board has considered matters not contained in the complaint served upon Slagle and where a Board based its findings on those matters not contained in the complaint that such conduct by the Board was a lack of due process and was unconstitutional requiring the Board’s decision to be reversed. Likewise the Board in the case at bar has made findings based on matters not contained in the First Amended Complaint and such conduct of the Board requires reversal of the Board’s decision in the present case. Further the Board has failed the reasoning mind test as set forth by the North Dakota Supreme Court in case after case (as provided in this brief for the Court and set forth above). Such test requires that "...a reasoning mind could have reasonably decided that the Board’s factual conclusions are supported by the weight of the evidence". Dr. Gale respectfully submits that the Board’s conclusions are not supported by the weight of the evidence thereby requiring that the Board’s decision be reversed. In addition, the Board’s findings are not supported by a preponderance of the evidence which section 28-32-19 (5), N.D.C.C. provides is a basis for reversal of the Board’s decision. Lastly, the Board’s failure to address what the standard of care or minimum standard of care is for each of the five complaints is a basis for reversal of the Board’s decision since section 43-05-16(1)(k), N.D.C.C. requires the Board to address the minimal standard of care. The Board’s findings, conclusions and order imposing discipline against Dr. Gale should be reversed and all five complaints should be dismissed.

In the event the Court agrees with Dr. Gale’s appeal, then Dr. Gale requests that he be awarded reasonable attorney fees and costs as provided by section 28-32-21.1, N.D.C.C.

Respectfully submitted this 4th day of October, 2000.

 

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James L. Norris - ID # 04138

Attorney for Appellant
James L. Norris, P.C.
P.O. Box 978
Bismarck, ND 58502-0978
(701) 255-2310

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above Dr. Gale’s Brief on Appeal of the Board’s Administrative Decision was personally delivered on October 4, 2000 to the following:

Gary R. Thune
Attorney at Law
314 East Thayer Avenue
Bismarck, ND 58501

 

____________________________________

James L. Norris
Attorney for Appellant