Oregon Medical Board v. KGW Complaint

6/8/2023 4:28 PM
23CV23025
4 IN THE CIRCUIT COURT OF THE STATE OF OREGON

5 FOR THE COUNTY OF MULTNOMAH
6 OREGON MEDICAL BOARD,
7 Plaintiff, Case No.
8 v. COMPLAINT
(DECLARATORY RELIEF)
9 KING BROADCASTING COMPANY dba
KGW; JOHN TIERNEY, Fee Authority: ORS 21.135(1), (2)(g)
10
State fees deferred at filing pursuant to
11 Defendants. ORS 20.140
12 CLAIM NOT SUBJECT TO

MANDATORY ARBITRATION
13
14
15
16
Plaintiff Oregon Medical Board (“OMB” or “the Board”) alleges:
17
1.
18
The Attorney General has ordered OMB to disclose certain records requested by
19
defendants KGW and John Tierney (“Defendants”) containing information relating to a Board
20
licensee.1 However, the Oregon Public Records Law (ORS 192.001, et seq.) and statutes
21
regulating health professional regulatory boards exempt the records at issue, to the extent they
22
are confidential, from public disclosure. Pursuant to ORS 192.411 and ORS 192.431, OMB
23
seeks a judicial ruling declaring that the records the Attorney General has ordered OMB to
24
disclose are not subject to disclosure.
25
1
At the time of this filing, the subject of this public records request is practicing in another state
26
and therefore has an inactive license with OMB. For purposes of this Complaint, this individual
will be referred to as “Licensee.”
COMPLAINT K E L L E R R O H R B A C K L. L. P .
1 805 S.W. Broadway, Suite 2750
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 PARTIES, JURISDICTION, AND VENUE
2 2.
3 Plaintiff Oregon Medical Board is an agency of the State of Oregon, and is located in
4 Multnomah County, Oregon.
5 3.
6 Defendant King Broadcasting Company dba KGW (“KGW”) is a corporation organized
7 under the laws of the State of Washington. Its principal place of business is located in Fairfax
8 County, Virginia. KGW regularly conducts business in Multnomah County.
9 4.
10 Defendant John Tierney (“Tierney”) is an Assistant News Director for KGW and, on
11 information and belief, a resident of Multnomah County, Oregon.
12 5.
13 The Circuit Court for the County of Multnomah has subject matter jurisdiction over this
14 proceeding under ORS 192.411, ORS 192.431 and ORS 28.010.
15 6.
16 OMB’s administrative offices are in Multnomah County. OMB holds records relating to
17 licensees at its administrative offices. Venue is proper in the Circuit Court for Multnomah
18 County pursuant to ORS 192.411(2).
19 FACTUAL ALLEGATIONS
20 7.
21 The Oregon Medical Board is a state agency and health professional regulatory board.
22 ORS 676.160(12). OMB regulates the practice of medicine in Oregon through its licensing of
23 health care providers. OMB’s mission is to protect the health, safety, and wellbeing of Oregon
24 citizens by regulating the practice of medicine in a manner that promotes access to quality care.
25 As part of its mandate, OMB is responsible for investigating licensees and when necessary,
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 imposing discipline. Where appropriate, OMB also rehabilitates and educates licensees. See, e.g.,
2 ORS 677.265.
3 8.
4 On March 7, 2023, KGW News, through its reporter Ashley Korslien, submitted a letter
5 to OMB (“KGW’s Request”). In the letter, KGW requested “the letter of concern issued to
6 [Licensee] in 2020 or 2021, and any records related to the board’s investigation of the complaints
7 that were resolved by the letter of concern.” The records responsive to KGW’s Request are
8 referred to herein as the “Requested Records.”
9 9.
10 On April 13, 2023, while declining to confirm the existence of an investigation or letter
11 of concern due to the confidentiality provisions of ORS 676.165 and ORS 676.175, OMB denied
12 KGW’s Request on the basis that KGW had not demonstrated by clear and convincing evidence
13 that public interest in disclosure of any potential records at issue outweighed other interests in
14 nondisclosure. OMB also sent to KGW a prior Attorney General Public Records Order on a
15 similar request, to support its reasoning.
16 10.
17 On May 1, 2023, KGW Assistant News Director Tierney petitioned the Attorney
18 General, pursuant to ORS 192.401 and ORS 192.411, seeking a review of OMB’s denial of
19 KGW’s Request and an order directing OMB to disclose the Requested Records.
20 11.
21 On May 10, 2023, counsel for Licensee sent to the Attorney General a response on
22 Licensee’s behalf to Tierney’s Petition for a public records order.
23 12.
24 On May 12, 2023, Tierney submitted to the Attorney General a response to the
25 submission from Licensee’s counsel.
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 13.
2 On May 25, 2023, the Attorney General issued a Public Records Order (the “Order”).
3 The Order granted Tierney’s Petition in part, stating that OMB was to provide Mr. Tierney with
4 certain documents (“Documents at Issue”) within the Requested Records, but denying Tierney’s
5 Petition as to the remaining Requested Records.
6 14.
7 On information and belief, as of the time of this Complaint, the Order is not in the public
8 domain. Given that the information in the Order is not in the public domain at this time, Plaintiff
9 will present to the Court for review, in camera or otherwise, the Order and other necessary
10 documents, at the appropriate time.
11 15.
12 On June 1, 2023, and pursuant to ORS 192.411(2), OMB gave timely written notice to
13 Defendants of OMB’s intention to institute proceedings in the Circuit Court for Multnomah
14 County to seek declaratory relief, injunctive relief, or both, from the Attorney General’s Order.
15 OMB sent a copy of this notice to the Attorney General. Defendants did not give timely notice of
16 any intent to seek declaratory or injunctive relief relating to any aspect of the Attorney General’s
17 Order.
18 16.
19 OMB maintains that the Requested Records, including the Documents at Issue, are
20 exempt from disclosure. By this action, OMB seeks a ruling that the Documents at Issue that the
21 Attorney General has ordered OMB to disclose are not subject to disclosure, because such
22 documents are confidential, and there is no clear and convincing evidence that the public interest
23 in disclosure outweighs interests in nondisclosure.
24 17.
25 The Documents at Issue are exempt from public disclosure to the extent they contain
26 confidential information and may be records of a Board investigation, or materials or documents
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 supporting that investigation (see ORS 676.165, ORS 676.175, ORS 677.425), and the public’s
2 interest in disclosure does not outweigh the interests in nondisclosure. To the contrary, disclosure
3 of the Documents at Issue, to the extent they contain confidential information and may be
4 records of a Board investigation, would harm the public interest by preventing the Oregon
5 Medical Board from effectively regulating and overseeing the licensure of health professionals to
6 protect the health, safety, and wellbeing of Oregon citizens, and set a precedent that would
7 eviscerate the confidentiality protections afforded to OMB’s investigatory processes by the State
8 legislature.
9 18.
10 The Documents at Issue, to the extent they contain confidential information and may be
11 records of a Board investigation, are also exempt from public disclosure to the extent they are
12 records containing information of a personal nature, ORS 192.355(2)(a), or information
13 submitted to a public body in confidence that is not otherwise required by law to be submitted,
14 ORS 192.355(4).
15 19.
16 For documents that are confidential under ORS 676.165 and 676.175, Defendants have
17 the burden of demonstrating by clear and convincing evidence “that the public interest in
18 disclosure outweighs other interests in nondisclosure, including but not limited to the public
19 interest in nondisclosure.” ORS 192.401(2)(a). For documents of a personal nature that are
20 exempt from disclosure under ORS 192.355(2)(a), Defendants must show by clear and
21 convincing evidence that the public interest requires disclosure in this particular instance and
22 bear the burden to show that public disclosure would not constitute an unreasonable invasion of
23 privacy. ORS 192.355(2)(a). For any documents containing information submitted to OMB in
24 confidence and not otherwise required by law, Defendants have the burden of proving that the
25 public body did not satisfy the requirements under ORS 192.355(4) to justify nondisclosure.
26 ORS 192.355(4).
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 FIRST CLAIM OF EXEMPTION – ORS 677.165, ORS 677.175, and ORS 677.425
2 20.
3 Paragraphs 1 to 19 are incorporated by reference herein.
4 21.
5 When the Board receives a complaint or mandatory report about one of its licensees or
6 applicants, ORS 676.165 and ORS 676.175 regulate and afford confidentiality to the OMB’s
7 investigation process, whereby OMB investigates the complaint or mandatory report to
8 determine whether there has been a violation of the Medical Practice Act, ORS 677.010, et seq.
9 (“MPA”). See, e.g., ORS 677.190 (Grounds for suspending, revoking or refusing to grant license,
10 registration or certification). ORS 676.165 details the process by which an investigator is
11 assigned, the manner in which evidence is collected, what the investigator may consider in
12 issuing a report, and the time in which a report must issue. ORS 676.165(5) provides that any
13 “[i]nvestigatory information obtained by an investigator and the report issued by the investigator
14 shall be exempt from public disclosure.”
15 22.
16 ORS 676.175 provides that any information obtained by the Board as part of an
17 investigation—including “complaints concerning licensee or applicant conduct and information
18 permitting the identification of complainants, licensees or applicants”—shall be confidential.
19 ORS 676.175(1). Further, if the Board votes not to impose a disciplinary sanction following an
20 investigation, information obtained as part of the investigation is only subject to disclosure if the
21 requesting party demonstrates by “clear and convincing evidence that the public interest in
22 disclosure outweighs other interests in nondisclosure, including but not limited to the public
23 interest in nondisclosure.” ORS 676.175(2)(a).
24 23.
25 The confidentiality afforded to OMB’s investigatory process is so critical that ORS
26 676.175(5)(a) specifies that for investigations for which the Board’s own conduct is not at issue,
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 only four documents related to the process are subject to public disclosure: (1) notice of intent to
2 impose disciplinary sanction against licensee or applicant that has been issued by vote of the
3 board; (2) final order that results from board's notice of intent to impose disciplinary sanction;
4 (3) emergency suspension order; and (4) consent order or stipulated agreement that involves
5 licensee or applicant conduct. ORS 676.165(5)(a)(A)-(D).
6 24.
7 An OMB investigation may be triggered by a complaint or by mandatory reporting
8 required under ORS 677.415. If a licensee has information that appears to show that a licensee is
9 or may be medically incompetent or guilty of unprofessional or dishonorable conduct, such
10 licensee is required to report such information to OMB. ORS 677.415(3). Under ORS
11 677.415(5), a health care facility is also required to report to the OMB any official action taken
12 against a licensee. Such mandatory reporting under ORS 677.415 is confidential “as provided
13 under ORS 676.175.” ORS 677.425(1).
14 25.
15 If an investigation results in a finding that there are grounds for discipline of a licensee
16 under ORS 677.190, OMB may discipline the licensee, including by suspending or revoking a
17 license to practice. When there is a finding of an MPA violation, a cover letter is sent with a
18 Notice of Proposed Discipline—a public, non-confidential document. ORS 676.175(5)(a)(A); see
19 supra Paragraph 23.
20 26.
21 For all investigations that do not result in a finding of an MPA violation, OMB sends a
22 closure letter to the subject of the investigation, indicating that the investigation has been closed.
23 In addition to a closure letter, the Board may also, at its discretion, issue a letter of concern.
24 Letters of concern are intended to provide feedback to the licensee and may include
25 recommendations for actions the licensee might take to improve patient care. Consequently, such
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 letters of concern are valuable to the OMB in protecting the health, safety, and wellbeing of
2 Oregon citizens by encouraging behavior that results in continued access to quality care.
3 27.
4 Because letters of concern and closure letters conclude an investigation, they may include
5 private health information of licensees, patients, and witnesses. More critically, the mere
6 existence of a closure letter or letter of concern reveals confidential information about the
7 licensee—specifically, that OMB received a complaint or mandatory report about the licensee
8 that triggered an investigation, even if there was ultimately no finding of wrongdoing. Simply
9 put, OMB would not issue closure letters and letters of concern if they were not confidential and
10 protected from public disclosure.
11 28.
12 To the extent any of the Documents at Issue contain confidential information, are records
13 of a Board investigation, and relate to the investigatory procedures laid out in ORS 676.165 and
14 ORS 676.175, they are confidential and exempt from disclosure under ORS 676.165, ORS
15 676.175, and ORS 677.425, because the documents were obtained as part of an investigation or
16 contain information that was obtained during an investigation.
17 29.
18 Defendants cannot demonstrate by clear and convincing evidence that public interest in
19 disclosure of the Documents at Issue outweighs other interests in nondisclosure. Requiring
20 disclosure of documents that may begin (e.g., a complaint or a mandatory report) or conclude
21 (e.g., a letter of concern or closure letter) an investigation that does not result in discipline will
22 harm the public’s interest because such disclosure will discourage candor and cooperation of
23 licensees during OMB investigations, voluntary assessments, and other rehabilitation processes;
24 inhibit licensees and health care facilities from divulging important details in their mandatory
25 reports, thereby causing undue delay to OMB investigations; and critically, discourage OMB
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 from issuing documents which may recommend actions licensees may take to improve patient
2 care.
3 30.
4 Specifically, requiring disclosure of any Documents at Issue that may begin and are
5 obtained as part of an investigation, including patient complaints or mandatory reports, will harm
6 the public’s interest because such disclosure (1) exposes licensees to the perception of wrongful
7 behavior even when complaints are unfounded; (2) discourages what doctors and medical
8 practices disclose in their mandatory reports; (3) potentially violates the privacy of complainants,
9 witnesses and patients, negatively impacting reporting of complaints and causing fear of
10 retaliation; and (4) removes the autonomy that is statutorily delegated to OMB to determine
11 when discipline is appropriate.
12 31.
13 Further, requiring disclosure of any Documents at Issue that may relate to the conclusion of
14 OMB investigatory processes under ORS 676.165 and ORS 676.175 will harm the public’s
15 interest because such disclosure will (1) reveal the existence of an investigation even when such
16 investigation is triggered by a meritless complaint or a complaint that results in no disciplinary
17 action; (2) discourage OMB from providing candid information and recommendations in
18 documents closing investigations that do not result in discipline, and from using such documents
19 as a tool to educate licensees and provide oversight; (3) increase the significance of what such
20 closure documents mean in the investigatory process and therefore impact how often and the
21 manner in which OMB issues them; and (4) encourage the public to incorrectly perceive closure
22 letters and letters of concern as disciplinary actions or evidence that the licensee did something
23 wrong.
24 SECOND CLAIM OF EXEMPTION – ORS 192.355
25 32.
26 Paragraphs 1 to 31 are incorporated by reference herein.
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 33.
2 ORS 192.355 establishes categories of public records that are presumptively exempt from
3 disclosure.
4 34.
5 ORS 192.355(2)(a) provides that “[i]nformation of a personal nature[,] such as but not
6 limited to that kept in a personal, medical or similar file” is exempt from disclosure “if public
7 disclosure would constitute an unreasonable invasion of privacy[.]” For the reasons already
8 stated, Defendants cannot show by clear and convincing evidence that the public interest in
9 disclosure outweighs the privacy concerns protected by ORS 192.355(2)(a) and the other statutes
10 cited herein.
11 35.
12 ORS 192.355(4) provides that information supplied to a public body in confidence is
13 exempt from disclosure if (1) the information is submitted to a public body voluntarily; (2) the
14 information is submitted in confidence; (3) the public body can show that the nature of
15 information should be kept confidential; (4) the public body has obliged itself in good faith to
16 maintain confidentiality; and (5) disclosure may harm the public interest.
17 36.
18 To the extent any of the Documents at Issue may relate to an investigation, the Board
19 during that investigation must determine whether the licensee’s conduct falls within any of the
20 categories that provide grounds for discipline. ORS 677.190, ORS 677.205. As stated in
21 Paragraph 26, if the investigation does not result in a finding of an MPA violation, the Board will
22 send a closure letter to the licensee or applicant advising that the investigation has concluded.
23 The Board may also, in its discretion, issue a letter of concern to a licensee or applicant.
24 37.
25 When OMB chooses to send a letter of concern, it may share confidential resources and
26 recommendations to provide support and feedback to the licensee, on the understanding that such
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 letters are protected and confidential. Oregon law protects this important public policy by
2 exempting letters of concern from public disclosure. Significantly, even if a letter of concern or
3 closure letter does not contain confidential information, the mere existence of such documents
4 necessarily reveals that an investigation occurred, creating the perception that the licensee or
5 applicant has done something wrong, even if no violation was found, or the complaint was
6 unfounded.
7 38.
8 As alleged herein, given the confidentiality protections afforded to OMB’s investigation
9 process under ORS 676.165 and ORS 676.175, OMB must oblige itself in good faith to maintain
10 the confidentiality of the Documents at Issue, to the extent they contain information voluntarily
11 submitted to OMB in confidence that should be kept confidential, and such records are not
12 subject to public disclosure. To the extent any of the Documents at Issue relate to the initiation or
13 outcome of an investigation that did not result in discipline, these documents will contain
14 personal or medical information of the licensee, including that an investigation has ensued, even
15 though no wrongdoing was found. Such documents may also include personal or medical
16 information of witnesses or patients.
17 39.
18 Disclosure of the Documents at Issue will harm the public interest because such
19 disclosure threatens the privacy concerns of OMB’s licensees and applicants and other
20 individuals involved in the Board’s investigation processes, including patients and witnesses.
21 Requiring disclosure in this instance would substantially chill the willingness of medical
22 providers, health care organizations, witnesses, patients, and members of the public to make
23 complaints and participate in investigations, and ultimately, harm the public’s interest in the
24 Oregon Medical Board fulfilling its statutory role to regulate licensees and applicants with regard
25 to patient care.
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 WHEREFORE, Plaintiff Oregon Medical Board prays for judgment as follows:
2 1. A finding and declaration that the documents ordered to be disclosed by the
3 Attorney General are exempt from disclosure and therefore protected from disclosure to
4 Defendants KGW and Tierney;
5 2. A finding and declaration that Plaintiff Oregon Medical Board is the prevailing
6 party;
7 3. An award of Plaintiff’s reasonable costs and disbursements incurred herein; and
8 4. Such other relief as the Court deems just and equitable.
9
DATED this 8th day of June, 2023.
10
StandardSig KELLER ROHRBACK L.L.P.
11
12
13 By s/ Joshua L. Ross
Joshua L. Ross, #034387
14 Yoona Park, #077095
Sarah R. Osborn, #222119
15 805 SW Broadway, Suite 2750
Portland, OR 97205
16 (971) 253-4600
jross@kellerrohrback.com
17 ypark@kellerrohrback.com
sosborn@kellerrohrback.com
18
Attorneys for Plaintiff Oregon Medical Board
19
20
21
22
23
24
25
26
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384
1 CERTIFICATE OF SERVICE
2 I hereby certify that I caused to be served a correct copy of the foregoing COMPLAINT
3 on the following named person(s) on the date and manner indicated below, addressed to said
4 person(s) at the address of each shown below per UTCR 21.100 as follows:
[X] By Hand Delivery
5 King Broadcasting Company dba KGW [ ] By Overnight Delivery
c/o Registered Agent CT Corporation System [ ] By Facsimile Pursuant to ORCP 9 F
6
780 Commercial St SE Ste 100 [ ] By U.S. Mail with postage prepaid
7 Salem OR 97301 [ ] By E-Mail Pursuant to ORCP 9 G
[ ] Electronically by OJD E-File &
8 Serve at the party’s email address as
recorded on the date of service in the
9 eFiling system pursuant to UTCR 21.100.
10
[X] By Hand Delivery
11 John Tierney c/o KGW [ ] By Overnight Delivery
c/o Registered Agent CT Corporation System [ ] By Facsimile Pursuant to ORCP 9 F
12 780 Commercial St SE Ste 100 [ ] By U.S. Mail with postage prepaid
Salem OR 97301 [ ] By E-Mail Pursuant to ORCP 9 G
13 [ ] Electronically by OJD E-File &
14 Serve at the party’s email address as
recorded on the date of service in the
15 eFiling system pursuant to UTCR 21.100.
16 DATED this 8th day of June, 2023.
17 StandardSig KELLER ROHRBACK L.L.P.
18
19 By s/ Joshua L. Ross
Joshua L. Ross, #034387
20 Yoona Park, #077095
Sarah R. Osborn, #222119
21 805 SW Broadway, Suite 2750
Portland, OR 97205
22 (971) 253-4600
jross@kellerrohrback.com
23 ypark@kellerrohrback.com
sosborn@kellerrohrback.com
24
Attorneys for Plaintiff Oregon Medical Board
25
, v. 1
26 , v. 1
Portland, OR 97205
TELEPHONE: (971) 253-4600
FACSIMILE: (206) 623-3384

Oregon Medical Board v. KGW Complaint

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Oregon Medical Board v. KGW Complaint

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6/8/2023 4:28 PM

4 IN THE CIRCUIT COURT OF THE STATE OF OREGON

6 OREGON MEDICAL BOARD,

7 Plaintiff, Case No.

12 CLAIM NOT SUBJECT TO

4 Multnomah County, Oregon.

6 Defendant King Broadcasting Company dba KGW (“KGW”) is a corporation organized

8 County, Virginia. KGW regularly conducts business in Multnomah County.

11 information and belief, a resident of Multnomah County, Oregon.

14 proceeding under ORS 192.411, ORS 192.431 and ORS 28.010.

18 County pursuant to ORS 192.411(2).

8 referred to herein as the “Requested Records.”

15 similar request, to support its reasoning.

22 Licensee’s behalf to Tierney’s Petition for a public records order.

25 submission from Licensee’s counsel.

5 Petition as to the remaining Requested Records.

10 documents, at the appropriate time.

23 in disclosure outweighs interests in nondisclosure.

26 confidential information and may be records of a Board investigation, or materials or documents

12 records containing information of a personal nature, ORS 192.355(2)(a), or information

3 Paragraphs 1 to 19 are incorporated by reference herein.

7 investigation process, whereby OMB investigates the complaint or mandatory report to

10 registration or certification). ORS 676.165 details the process by which an investigator is

14 shall be exempt from public disclosure.”

17 investigation—including “complaints concerning licensee or applicant conduct and information

18 permitting the identification of complainants, licensees or applicants”—shall be confidential.

23 interest in nondisclosure.” ORS 676.175(2)(a).

25 The confidentiality afforded to OMB’s investigatory process is so critical that ORS

5 licensee or applicant conduct. ORS 676.165(5)(a)(A)-(D).

7 An OMB investigation may be triggered by a complaint or by mandatory reporting

9 or may be medically incompetent or guilty of unprofessional or dishonorable conduct, such

13 under ORS 676.175.” ORS 677.425(1).

18 Notice of Proposed Discipline—a public, non-confidential document. ORS 676.175(5)(a)(A); see

19 supra Paragraph 23.

10 protected from public disclosure.

16 contain information that was obtained during an investigation.

19 disclosure of the Documents at Issue outweighs other interests in nondisclosure. Requiring

11 when discipline is appropriate.

16 investigation is triggered by a meritless complaint or a complaint that results in no disciplinary

24 SECOND CLAIM OF EXEMPTION – ORS 192.355

26 Paragraphs 1 to 31 are incorporated by reference herein.

12 ORS 192.355(4) provides that information supplied to a public body in confidence is

8 As alleged herein, given the confidentiality protections afforded to OMB’s investigation

16 information of witnesses or patients.

2 1. A finding and declaration that the documents ordered to be disclosed by the

4 Defendants KGW and Tierney;

7 3. An award of Plaintiff’s reasonable costs and disbursements incurred herein; and

8 4. Such other relief as the Court deems just and equitable.

16 DATED this 8th day of June, 2023.

17 StandardSig KELLER ROHRBACK L.L.P.

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