Chancellor John Rambo, Chief Judge (Eastern Grand Division)
Judge A. Blake Neill (Western Grand Division)
Judge Danna Bill Johnson (Middle Grand Division)
In this matter, Plaintiff, a licensed physician, seeks declaratory and injunctive relief challenging the constitutionality of Tenn. Code Ann. § 63-1-170. This statute mandates the automatic revocation of a medical license upon conviction of certain criminal offenses. Dr. Reach contends that the automatic revocation provision violates the Due Process Clauses of both the United States Constitution and the Tennessee Constitution, arguing that physicians are entitled to notice and an opportunity to be heard before their professional license is revoked.
The panel concluded that the constitutionality of Tennessee Code Annotated § 63-1-170(b), does not violate due process because Dr. Reach received a full opportunity to be heard in his underlying federal criminal proceedings, and it rejected his claims that the law is unconstitutionally vague or arbitrary and capricious. The Court also found that the automatic revocation did not violate other Tennessee statutes, as § 63-1-170(b) expressly applies notwithstanding any other law.