A West Virginia licensed physician applied for a license to practice in North Dakota. Her application was denied for not reporting (on advice from counsel) her termination from a New York residency program. The information was then reported by the North Dakota Medical Board to the National Practitioner Data Bank, and her license was subsequently revoked in West Virginia.

The physician sued, among others, the director of the New York school who had reported her termination to the North Dakota Medical Board. She alleged that the reporter knew the report was false and meant only to result in denial of her license application. The U.S. District Court, District of Columbia, dismissed the case due to lack of personal jurisdiction. The physician had alleged that the defendant licensure boards and the residency program were doing business in D.C. when they made reports to the Secretary of Health and Human Services who maintains the Data Bank. The court found this communication was not enough "business" to warrant a party to reasonably expect to have to travel to D.C. to defend itself.