People v. Dobkin, 34 N.Y.2d 561 (1974)

Statutes and regulations requiring licenses for medical facilities must be narrowly tailored to clearly define the types of enterprises subject to licensing, avoiding overly broad language that could encompass individual or small-group medical practices.

Summary

The New York Court of Appeals affirmed the Appellate Division’s order, holding that the statute and regulations governing the licensing of institutional medical care facilities were too broad. The terms “facility” and “clinic” were deemed inclusive of many types of individual, partnership, and group medical practices not intended to be licensed. The court found the language ambivalent regarding whether it referred to physical resources or functional personnel involved in medical treatment, causing particular frustration in this case. The court clarified that this ruling should not prevent the drafting of statutes or regulations that accurately describe the specific types of enterprises requiring licensing, such as specialized, large-scale abortion providers, as long as they comply with the Supreme Court’s decisions in Roe v. Wade and Doe v. Bolton.

Facts

The case concerned a medical practice, likely providing abortion services, that the state sought to license as an institutional medical facility. The specific details of the practice’s operations are not extensively detailed in the Court of Appeals memorandum opinion but were sufficient for the state to argue that it fell under the purview of existing licensing regulations.

Procedural History

The lower court ruled in favor of the People (the state), finding the medical practice was subject to licensing requirements. The Appellate Division reversed this decision. The Court of Appeals affirmed the Appellate Division’s order, effectively ruling against the state’s attempt to enforce licensing requirements on the medical practice.

Issue(s)

Whether the applicable statute and regulations governing the requirement of a license for an enterprise engaged in institutional medical care and treatment are overly broad, encompassing medical practices not intended to be subject to licensing.

Holding

Yes, because the terms “facility” and “clinic” are inclusive of many kinds of individual, partnership, and group medical practice, which concededly are not subject to or intended to be subject to licensing; and because the terms are ambivalent in whether they refer to physical as distinguished from functional or personnel resources used or available in the treatment of medical conditions.

Court’s Reasoning

The court found the licensing statute and regulations too broad and ambiguous. The terms “facility” and “clinic” could be interpreted to include routine medical practices that were never intended to be subject to institutional licensing requirements. The court emphasized the lack of clarity in whether the regulations targeted the physical infrastructure of a medical practice or the functional resources (personnel and services) it provided. This ambiguity created uncertainty and potentially subjected ordinary medical practices to unnecessary regulatory burdens. The court acknowledged the state’s interest in regulating specialized or large-scale medical enterprises, particularly those offering abortion services, but stressed that any such regulation must be carefully drafted to avoid infringing on the constitutional rights established in Roe v. Wade and Doe v. Bolton. The court stated that it “is not intended to inhibit the drafting and application of statute or regulations which accurately describe the kinds of enterprise to be licensed, including perhaps the specialized, large-scale handling of abortions by institutional enterprises or those held out as providing the varied services of an institutional enterprise, subject, of course, to the strictures laid down in Roe v. Wade (410 U. S. 113) and Doe v. Bolton (410 U. S. 179).” Judges Burke and Gabrielli dissented, voting to reverse based on the dissenting opinion at the Appellate Division, suggesting they believed the licensing requirements were appropriately applied in this case.