Laurino v. Bd. of Prof’l Discipline of the Idaho State Bd. of Med.

Laurino v. Bd. of Prof’l Discipline of the Idaho State
Bd. of Med.,
No. 27131 (Idaho May 1, 2002)

The
Idaho State Board revoked a physician’s license to practice medicine. The physician
sued, and the State Board’s decision was reversed by a lower court. The State
Board then appealed. The Supreme Court of Idaho ruled that the Board’s decision
must be affirmed unless its findings are not supported by substantial evidence
on the record as a whole. The court also ruled that findings made by the Board
on matters outside the record must be reversed as unsupported by substantial,
competent evidence or as arbitrary and capricious. The court found that the
physician could not have violated a local standard of care when either the local
standard of care was undefined in the record or a patient’s conduct prevented
the physician from following the defined standard of care.