Rochling v. Dept. of VA, et al., No. 12-2828 (8th Cir. 2013)
Annotate this CaseAfter a patient's death, the patient's family sued the VA for medical malpractice. The VA settled with the family and determined that the settlement was "for the benefit of" plaintiff, who was a treating physician. Plaintiff then filed suit against the VA alleging violations of his due process rights and violations of the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq. The court concluded that the district court did not err by dismissing the procedural due process claim because plaintiff failed to plead the deprivation of a constitutionally protected interest; the district court did not err by dismissing plaintiff's substantive due-process claim because plaintiff's pleadings were insufficient; the VA's factfinding procedures were adequate and the district court properly rejected de novo review; the district court did not grossly abuse its discretion by denying plaintiff's motion to supplement the record; and the VA's decision was not arbitrary or capricious, and the district court did not err by granting summary judgment. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Administrative Procedure Act. In action claiming the VA violated the APA and plaintiff's substantive and due process rights when it reported a settlement to the National Practitioner Data Bank, the district court did not err in dismissing the procedural due process claim as plaintiff's claim that the report injured him was speculative and conclusory and failed to plead a deprivation of a constitutionally protected interest; the complaint failed to state a claim for a violation of substantive due process; the VA's fact finding procedures were adequate and the district court applied the proper review standard - arbitrary and capricious - rather than de novo review; the district court did not grossly abuse its discretion in denying plaintiff's request to supplement the administrative record; the VA's decision in the matter was not arbitrary or capricious, and the district court did not err in granting the VA's motion for summary judgment.
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