Solomon Adu-Beniako, M.D.; Decision and Order, 5990-5992 [2020-01971]
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5990
Federal Register / Vol. 85, No. 22 / Monday, February 3, 2020 / Notices
because Registrant has no valid medical
license in California . . . [and] is
without state authority to handle
controlled substances in California, the
state where he is registered with DEA.’’
Id. at 3.
Based on the DI’s Declaration, the
Government’s written representations,
and my review of the record, I find that
the Government accomplished service
of the OSC on Registrant on May 29,
2019. I also find that more than thirty
days have now passed since the
Government accomplished service of
the OSC. Further, based on the
Government’s written representations, I
find that neither Registrant, nor anyone
purporting to represent the Registrant,
requested a hearing, submitted a written
statement while waiving Registrant’s
right to a hearing, or submitted a
corrective action plan. Accordingly, I
find that Registrant has waived the right
to a hearing and the right to submit a
written statement and corrective action
plan. 21 CFR 1301.43(d) and 21 U.S.C.
824(c)(2)(C). I, therefore, issue this
Decision and Order based on the record
submitted by the Government, which
constitutes the entire record before me.
21 CFR 1301.43(e).
Findings of Fact
Registrant’s DEA Registration
Registrant is the holder of DEA
Certificate of Registration No.
BH6439714 at the registered address of
4401 N. Atlantic Ave., 101, Long Beach,
California 90807. RFAA, EX 1
(Certification of Registration History).
Pursuant to this registration, Registrant
is authorized to dispense controlled
substances in schedules II through V as
a practitioner. Id. Registrant’s
registration expires on October 31, 2020,
and is ‘‘in an active pending status.’’ Id.
The Status of Registrant’s State License
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On July 23, 2018, Registrant
surrendered his California Physician’s
and Surgeon’s Certificate pursuant to an
Agreement for Surrender of License
(hereinafter, Agreement) that he entered
into with the Board.1 RFAA, EX 3
(Agreement). According to the
Agreement, Registrant surrendered his
medical license following a Board
Decision effective on May 18, 2018,
1 The Government’s evidence includes a letter of
certification submitted by the Executive Director of
the Medical Board of California, certifying the
surrender of Registrant’s Physician’s and Surgeon’s
Certificate. RFAA, EX 3, at 1. The letter also
certifies prior disciplinary action against Registrant,
including an Order Restricting the Practice of
Medicine issued by the Superior Court of Riverside
County on November 23, 2015, and an Accusation
and First Amended Accusation filed against
Registrant in May and July, 2017. Id.
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‘‘wherein [Registrant’s] license was
revoked, with the revocation stayed, and
placed on seven [ ] years’ probation with
various standard terms and conditions.’’
Id. at 2. The Board Decision provided
that ‘‘ ‘if [Registrant] ceases practicing
due to retirement, health reasons, or is
unable to satisfy the terms and
condition of probation, [Registrant] may
request to surrender his . . . license.’ ’’
Id. Pursuant to the Agreement,
Registrant agreed that he ‘‘understands
he will no longer be permitted to
practice as a physician and surgeon in
California.’’ Id. The Agreement further
provided that should Registrant ever file
an application for relicensure or
reinstatement in California, the Board
would treat it as a petition for
reinstatement of a revoked license. Id.
According to the website of the
California Department of Consumer
Affairs, of which I take official notice,
Registrant’s license remains
surrendered. 2 https://search.dca.ca.gov/
details/8002/A/68934/
f0e886931951cf8f0b2f2099fecad44b
(last visited January 3, 2020).
Accordingly, I find that Registrant
currently is not licensed to engage in the
practice of medicine in California, the
state in which he is registered with the
DEA.
This rule derives from the text of two
provisions of the CSA. First, Congress
defined the term ‘‘practitioner’’ to mean
‘‘a physician . . . or other person
licensed, registered, or otherwise
permitted, by . . . the jurisdiction in
which he practices . . ., to distribute,
dispense, . . . [or] administer . . . a
controlled substance in the course of
professional practice.’’ 21 U.S.C.
802(21). Second, in setting the
requirements for obtaining a
practitioner’s registration, Congress
directed that ‘‘[t]he Attorney General
shall register practitioners . . . if the
applicant is authorized to dispense . . .
controlled substances under the laws of
the State in which he practices.’’ 21
U.S.C. 823(f). Because Congress has
2 Under
the Administrative Procedure Act, an
agency ‘‘may take official notice of facts at any stage
in a proceeding—even in the final decision.’’
United States Department of Justice, Attorney
General’s Manual on the Administrative Procedure
Act 80 (1947) (Wm. W. Gaunt & Sons, Inc., Reprint
1979). Pursuant to 5 U.S.C. 556(e), ‘‘[w]hen an
agency decision rests on official notice of a material
fact not appearing in the evidence in the record, a
party is entitled, on timely request, to an
opportunity to show the contrary.’’ Accordingly,
Registrant may dispute my finding by filing a
properly supported motion for reconsideration
within 15 calendar days of the date of this Order.
Any such motion shall be filed with the Office of
the Administrator and a copy shall be served on the
Government. In the event Registrant files a motion,
the Government shall have 15 calendar days to file
a response.
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Sfmt 4703
clearly mandated that a practitioner
possess State authority in order to be
deemed a practitioner under the CSA,
the DEA has held repeatedly that
revocation of a practitioner’s registration
is the appropriate sanction whenever he
is no longer authorized to dispense
controlled substances under the laws of
the State in which he practices. See,
e.g., Hooper, supra, 76 FR at 71371–72;
Sheran Arden Yeates, M.D., 71 FR
39130, 39131 (2006); Dominick A. Ricci,
M.D., 58 FR 51104, 51105 (1993); Bobby
Watts, M.D., 53 FR 11919, 11920 (1988);
Blanton, supra, 43 FR at 27617.
According to the California Uniform
Controlled Substances Act, ‘‘No person
other than a physician . . . shall write
or issue a prescription.’’ Cal. Health &
Safety Code section 11150 (West 2019).
Further, ‘‘physician,’’ as defined by
California statute, is a person who is
‘‘licensed to practice’’ in California. Cal.
Health & Safety Code section 11024
(West 2019).
Here, the undisputed evidence in the
record is that Registrant currently lacks
authority to practice medicine in
California. As already discussed, a
physician must be a licensed
practitioner to dispense a controlled
substance in California. Thus, because
Registrant lacks authority to practice
medicine in California and, therefore, is
not authorized to handle controlled
substances in California, I will order
that Registrant’s DEA registration be
revoked.
Order
Pursuant to 28 CFR 0.100(b) and the
authority vested in me by 21 U.S.C.
824(a), I hereby revoke DEA Certificate
of Registration No. BH6439714 issued to
Kambiz Haghighi, M.D. Further, I
hereby deny any pending application of
Kambiz Haghighi, M.D., to renew or
modify this registration, as well as any
pending application of Kambiz
Haghighi, M.D., for registration in
California. This Order is effective March
4, 2020.
Dated: January 3, 2020.
Uttam Dhillon,
Acting Administrator.
[FR Doc. 2020–01969 Filed 1–31–20; 8:45 am]
BILLING CODE 4410–09–P
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
Solomon Adu-Beniako, M.D.; Decision
and Order
On September 12, 2019, the Assistant
Administrator, Diversion Control
Division, Drug Enforcement
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Administration (hereinafter, DEA or
Government), issued an Order to Show
Cause to Solomon Adu-Beniako, M.D,
(hereinafter, Registrant), of Southfield,
Michigan. Order to Show Cause
(hereinafter, OSC), at 1. The OSC
proposed the revocation of Registrant’s
Certificate of Registration No.
FA7485027 on the ground that
Registrant does ‘‘not have authority to
handle controlled substances in
Michigan, the state in which . . .
[Registrant is] registered with the DEA.’’
Id. (citing 21 U.S.C. 823(f) and
824(a)(3)).
Specifically, the OSC alleged that the
State of Michigan Board of Pharmacy
(hereinafter, Board) issued a Final Order
effective on July 21, 2019, which
revoked Registrant’s Michigan
controlled substance and drug controllocation licenses (5315023991,
5307004648 and 5307004717). Id. at 1–
2. The OSC alleged that because the
Board had not modified or lifted its
revocation order, Registrant lacks
authority to handle controlled
substances in the State of Michigan. Id.
at 2, citing 21 U.S.C. 802(21), 823(f) and
824(a)(3).
The OSC notified Registrant of the
right to request a hearing on the
allegations or to submit a written
statement while waiving the right to a
hearing, the procedures for electing each
option, and the consequences for failing
to elect either option. OSC, at 2 (citing
21 CFR 1301.43). The OSC also notified
Registrant of the opportunity to submit
a corrective action plan. Id. at 4 (citing
21 U.S.C. 824(c)(2)(C)).
Adequacy of Service
In a Declaration dated November 8,
2019, a Diversion Investigator
(hereinafter, DI) assigned to the Detroit
Division Office, detailed his
investigation in the matter involving
Registrant. Request for Final Agency
Action (hereinafter, RFAA), EX 8 (DI
Declaration), at 1–2. The DI stated that
he obtained a copy of the Michigan
Board of Pharmacy’s Final Order dated
June 21, 2019, and as a result of that
Final Order, DEA issued an Order to
Show Cause on Registrant. Id. at 2. He
further stated that on September 19,
2019, he and a DEA Special Agent
(hereinafter, SA) attempted to serve the
OSC on Registrant at Registrant’s
residence located at 31568 Bridge Street,
Livonia, Michigan, but received no
answer at that residence. Id. at 2.
According to the DI, DEA personnel
proceeded to Registrant’s most recent
place of employment, which was also
his registered address, located at 20905
Greenfield Road, Suite 702, Southfield,
Michigan, but the receptionist at that
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location ‘‘could not recall the last time
[Registrant] was in the office or when
[Registrant] was expected to report back
to that location.’’ Id. at 2–3. On the
following day, the DI spoke to Registrant
on the telephone, identified himself,
and arranged to meet with him at a
restaurant on that same day. Id. The DI
stated that he and the same SA met with
the Registrant, placed the OSC on the
table in front of him, and explained that
‘‘he was being served with an [OSC]
because he lacked state authority to
handle controlled substances in
Michigan and that he would not be able
to maintain a DEA registration without
such authorization.’’ Id. at 3. The DI
stated that Registrant pushed the
document away from him, and the SA
‘‘attempted to again explain the Order to
Show Cause process’’ to Registrant, at
which point Registrant ‘‘stood up and
quickly left the restaurant.’’ Id. at 3. The
DI ‘‘mentioned to [Registrant] that his
name appeared on the [OSC] document
and that he should not leave the
document on the table,’’ but Registrant
‘‘continued on to his automobile and
drove away.’’ Id. The DI and the SA
then left the restaurant with the OSC. Id.
The Government forwarded its RFAA,
along with the evidentiary record, to
this office on November 18, 2019. In its
RFAA, the Government contends that
despite Registrant’s refusal to take
possession of the OSC, he is deemed to
have been sufficiently served. RFAA, at
6. The Government requests a final
order holding that Registrant has waived
his opportunity for a hearing and
otherwise failed to respond to the Show
Cause Order, and revoking Registrant’s
DEA registration. Id. at 2.
Based on the DI’s Declaration, the
Government’s written representations,
and my review of the record, I find that
the Government accomplished service
of the OSC on Registrant on September
20, 2019. I find that the Government has
satisfied its obligation under the Due
Process Clause ‘‘to provide ‘notice
reasonably calculated, under all the
circumstances, to apprise interested
parties of the pendency of the action
and afford them an opportunity to
present their objections.’’’ Jones v.
Flowers, 547 U.S. 220, 226 (2006)
(quoting Mullane v. Central Hanover
Bank & Trust Co., 339 U.S. 306, 314
(1950)). In this case, the Government
tried to serve Registrant at his home and
his registered address—both of which
were locations where the Government
reasonably believed Registrant would be
located. RFAA, EX 8, at 2–3. When
those efforts failed, the DI contacted
Registrant by telephone and arranged an
in-person meeting, during which the DI
explained to Registrant the context of
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5991
the OSC. Id. at 3. Registrant repeatedly
refused to take possession of the OSC
during this meeting, even after its
relevance had been clearly
communicated to Registrant, and the DI
and SA made reasonable efforts to leave
the papers with Registrant. Id. Thus,
Registrant was reasonably apprised of
the pendency of the action and his
refusal to take possession of the papers
does not mean service was inadequate.
See United States v Miller, 2007 WL
3173362 (E.D. Mich. Oct. 29, 2007) (The
defendant of an institution of an action
against him ‘‘‘cannot claim that the
court has not [sic] authority to act when
he has willfully evaded the service of
process.’’’ (quoting Ali v. Mid-Atl.
Settlement Servs., Inc., 233 FRD. 32, 36
(D.D.C. 2006) (citation omitted))).1
I also find that more than thirty days
have now passed since the Government
accomplished service of the OSC.
Further, based on the Government’s
written representations, I find that
neither Registrant, nor anyone
purporting to represent the Registrant,
requested a hearing, submitted a written
statement while waiving Registrant’s
right to a hearing, or submitted a
corrective action plan. Accordingly, I
find that Registrant has waived the right
to a hearing and the right to submit a
written statement and corrective action
plan. 21 CFR 1301.43(d) and 21 U.S.C.
824(c)(2)(C). I, therefore, issue this
Decision and Order based on the record
submitted by the Government, which
constitutes the entire record before me.
21 CFR 1301.43(e).
Findings of Fact
Registrant’s DEA Registration
Registrant is the holder of DEA
Certificate of Registration No.
FA7485027 at the registered address of
20905 Greenfield Rd., Ste. 702,
Southfield, Michigan. RFAA, EX 2
(Certification of Registration History).
Pursuant to this registration, Registrant
is authorized to dispense controlled
substances in schedules II through V 2 as
1 See also Morgan v. United States, 304 U.S. 1,
18 (1938) (‘‘The right to a hearing embraces not only
the right to present evidence, but also a reasonable
opportunity to know the claims of the opposing
party and to meet them. . . . Those who are brought
into contest with the Government in a quasijudicial
proceeding aimed at the control of their activities
are entitled to be fairly advised of what the
Government proposes.’’) (emphasis added).
2 It is noted that the OSC mistakenly stated that
Registrant was a practitioner in ‘‘Schedules II–IIIN.’’
I find this to be harmless error in that the
Registration was appropriately identified by its
number and so the Registrant had adequate notice
of the registration subject to the proceeding.
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Discussion
Pursuant to 21 U.S.C. 824(a)(3), the
Attorney General is authorized to
suspend or revoke a registration issued
under section 823 of the Controlled
Substances Act (hereinafter, CSA),
‘‘upon a finding that the registrant . . .
has had his State license or registration
suspended . . . [or] revoked . . . by
competent State authority and is no
longer authorized by State law to engage
in the . . . dispensing of controlled
substances.’’ With respect to a
practitioner, the DEA has also long held
that the possession of authority to
dispense controlled substances under
the laws of the State in which a
practitioner engages in professional
practice is a fundamental condition for
obtaining and maintaining a
practitioner’s registration. See, e.g.,
James L. Hooper, M.D., 76 FR 71371
(2011), pet. for rev. denied, 481 Fed.
Appx. 826 (4th Cir. 2012); Frederick
Marsh Blanton, M.D., 43 FR 27616,
27617 (1978).
This rule derives from the text of two
provisions of the CSA. First, Congress
defined the term ‘‘practitioner’’ to mean
‘‘a physician . . . or other person
licensed, registered, or otherwise
permitted, by . . . the jurisdiction in
which he practices . . ., to distribute,
dispense, . . . [or] administer . . . a
controlled substance in the course of
professional practice.’’ 21 U.S.C.
802(21). Second, in setting the
requirements for obtaining a
practitioner’s registration, Congress
directed that ‘‘[t]he Attorney General
shall register practitioners . . . if the
applicant is authorized to dispense . . .
controlled substances under the laws of
the State in which he practices.’’ 21
U.S.C. 823(f). Because Congress has
clearly mandated that a practitioner
possess State authority in order to be
deemed a practitioner under the CSA,
the DEA has held repeatedly that
revocation of a practitioner’s registration
is the appropriate sanction whenever he
is no longer authorized to dispense
controlled substances under the laws of
the State in which he practices. See,
e.g., James L. Hooper, M.D., 76 FR at
71371–72; Sheran Arden Yeates, M.D.,
71 FR 39130, 39131 (2006); Dominick A.
Ricci, M.D., 58 FR 51104, 51105 (1993);
Bobby Watts, M.D., 53 FR 11919, 11920
(1988); Frederick Marsh Blanton, M.D.,
43 FR at 27617.
Under Michigan law, ‘‘a person who
manufactures, distributes, prescribes, or
dispenses a controlled substance in this
state . . . shall obtain a license issued
by the administrator.’’ Mich. Comp.
Laws § 333.7303(1). Here, the
3 Registrant is also authorized as a Data-Waiver
practitioner for up to 100 patients pursuant to 21
U.S.C. 823(g)(2)(a).
4 Under the Administrative Procedure Act, an
agency ‘‘may take official notice of facts at any stage
in a proceeding—even in the final decision.’’
United States Department of Justice, Attorney
General’s Manual on the Administrative Procedure
Act 80 (1947) (Wm. W. Gaunt & Sons, Inc., Reprint
1979). Pursuant to 5 U.S.C. 556(e), ‘‘[w]hen an
agency decision rests on official notice of a material
fact not appearing in the evidence in the record, a
party is entitled, on timely request, to an
opportunity to show the contrary.’’ Accordingly,
Registrant may dispute my finding by filing a
a practitioner.3 Registrant’s registration
expires on June 30, 2020, and is ‘‘in an
active pending status.’’ RFAA, EX 1
(Copy of Registrant’s Certificate of
Registration).
lotter on DSKBCFDHB2PROD with NOTICES
The Status of Registrant’s State License
On January 19, 2018, the Michigan
Department of Licensing and Regulatory
Affairs ‘‘executed an Order of Summary
Suspension and an Administrative
Complaint charging [Registrant] with
violating the Public Health Code, [Mich.
Comp. Laws] § 333.1101 et seq.’’ RFAA,
EX 3 (Final Order of the Board of
Pharmacy Disciplinary Subcommittee,
Bureau of Professional Licensing,
Michigan Department of Licensing and
Regulatory Affairs), at 1. On June 21,
2019, after an administrative hearing,
the Michigan Board of Pharmacy issued
a Final Order revoking Registrant’s
controlled substance license and drug
control-location licenses. Id. at 2, 4. The
Final Order became effective thirty days
from its signature, on July 21, 2019.
RFAA, EX 3, at 4.
According to Michigan’s online
records, of which I take official notice,4
Registrant’s controlled substance license
and drug control-location licenses
remain revoked. https://
aca3.accela.com/MILARA/
GeneralProperty/PropertyLookUp.aspx
(last visited January 3, 2020).
Further, the Final Order states that
reinstatement of Registrant’s revoked
licenses ‘‘is not automatic and shall be
in accordance with [Mich. Comp. Laws]
§§ 333.7315–333.7316.’’ RFAA, EX 3, at
3. It is noted that pursuant to Section
333.7315, Registrant may not apply for
reinstatement of his revoked licenses
before the expiration of five years after
the effective date of revocation. Mich.
Comp. Laws § 333.7315.
Accordingly, I find that Registrant
currently does not possess a controlled
substances license in Michigan, the
State in which he is registered with the
DEA.
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undisputed evidence in the record is
that Registrant currently lacks authority
to manufacture, distribute, prescribe, or
dispense controlled substances in
Michigan. Thus, because Registrant
lacks authority to distribute, prescribe,
or dispense controlled substances in
Michigan, Registrant is not eligible to
maintain a DEA registration.
Accordingly, I will order that
Registrant’s DEA registration be
revoked.
Order
Pursuant to 28 CFR 0.100(b) and the
authority vested in me by 21 U.S.C.
824(a), I hereby revoke DEA Certificate
of Registration No. FA7485027 issued to
Solomon Adu-Beniako. This Order is
effective March 4, 2020.
Dated: January 3, 2020.
Uttam Dhillon,
Acting Administrator.
[FR Doc. 2020–01971 Filed 1–31–20; 8:45 am]
BILLING CODE 4410–09–P
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
[Docket No. DEA–578]
Bulk Manufacturer of Controlled
Substances Application: IsoSciences,
LLC
ACTION:
Notice of application.
Registered bulk manufacturers of
the affected basic classes, and
applicants therefore, may file written
comments on or objections to the
issuance of the proposed registration on
or before April 3, 2020.
ADDRESSES: Written comments should
be sent to: Drug Enforcement
Administration, Attention: DEA Federal
Register Representative/DPW, 8701
Morrissette Drive, Springfield, Virginia
22152.
DATES:
In
accordance with 21 CFR 1301.33(a), this
is notice that on November 27, 2019,
IsoSciences, LLC, 340 Mathers Road,
Ambler, Pennsylvania 19002–3420
applied to be registered as a bulk
manufacturer of the following basic
classes of controlled substances:
SUPPLEMENTARY INFORMATION:
properly supported motion for reconsideration
within 15 calendar days of the date of this Order.
Any such motion shall be filed with the Office of
the Administrator and a copy shall be served on the
Government. In the event Registrant files a motion,
the Government shall have 15 calendar days to file
a response.
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Agencies
[Federal Register Volume 85, Number 22 (Monday, February 3, 2020)]
[Notices]
[Pages 5990-5992]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-01971]
-----------------------------------------------------------------------
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
Solomon Adu-Beniako, M.D.; Decision and Order
On September 12, 2019, the Assistant Administrator, Diversion
Control Division, Drug Enforcement
[[Page 5991]]
Administration (hereinafter, DEA or Government), issued an Order to
Show Cause to Solomon Adu-Beniako, M.D, (hereinafter, Registrant), of
Southfield, Michigan. Order to Show Cause (hereinafter, OSC), at 1. The
OSC proposed the revocation of Registrant's Certificate of Registration
No. FA7485027 on the ground that Registrant does ``not have authority
to handle controlled substances in Michigan, the state in which . . .
[Registrant is] registered with the DEA.'' Id. (citing 21 U.S.C. 823(f)
and 824(a)(3)).
Specifically, the OSC alleged that the State of Michigan Board of
Pharmacy (hereinafter, Board) issued a Final Order effective on July
21, 2019, which revoked Registrant's Michigan controlled substance and
drug control-location licenses (5315023991, 5307004648 and 5307004717).
Id. at 1-2. The OSC alleged that because the Board had not modified or
lifted its revocation order, Registrant lacks authority to handle
controlled substances in the State of Michigan. Id. at 2, citing 21
U.S.C. 802(21), 823(f) and 824(a)(3).
The OSC notified Registrant of the right to request a hearing on
the allegations or to submit a written statement while waiving the
right to a hearing, the procedures for electing each option, and the
consequences for failing to elect either option. OSC, at 2 (citing 21
CFR 1301.43). The OSC also notified Registrant of the opportunity to
submit a corrective action plan. Id. at 4 (citing 21 U.S.C.
824(c)(2)(C)).
Adequacy of Service
In a Declaration dated November 8, 2019, a Diversion Investigator
(hereinafter, DI) assigned to the Detroit Division Office, detailed his
investigation in the matter involving Registrant. Request for Final
Agency Action (hereinafter, RFAA), EX 8 (DI Declaration), at 1-2. The
DI stated that he obtained a copy of the Michigan Board of Pharmacy's
Final Order dated June 21, 2019, and as a result of that Final Order,
DEA issued an Order to Show Cause on Registrant. Id. at 2. He further
stated that on September 19, 2019, he and a DEA Special Agent
(hereinafter, SA) attempted to serve the OSC on Registrant at
Registrant's residence located at 31568 Bridge Street, Livonia,
Michigan, but received no answer at that residence. Id. at 2. According
to the DI, DEA personnel proceeded to Registrant's most recent place of
employment, which was also his registered address, located at 20905
Greenfield Road, Suite 702, Southfield, Michigan, but the receptionist
at that location ``could not recall the last time [Registrant] was in
the office or when [Registrant] was expected to report back to that
location.'' Id. at 2-3. On the following day, the DI spoke to
Registrant on the telephone, identified himself, and arranged to meet
with him at a restaurant on that same day. Id. The DI stated that he
and the same SA met with the Registrant, placed the OSC on the table in
front of him, and explained that ``he was being served with an [OSC]
because he lacked state authority to handle controlled substances in
Michigan and that he would not be able to maintain a DEA registration
without such authorization.'' Id. at 3. The DI stated that Registrant
pushed the document away from him, and the SA ``attempted to again
explain the Order to Show Cause process'' to Registrant, at which point
Registrant ``stood up and quickly left the restaurant.'' Id. at 3. The
DI ``mentioned to [Registrant] that his name appeared on the [OSC]
document and that he should not leave the document on the table,'' but
Registrant ``continued on to his automobile and drove away.'' Id. The
DI and the SA then left the restaurant with the OSC. Id.
The Government forwarded its RFAA, along with the evidentiary
record, to this office on November 18, 2019. In its RFAA, the
Government contends that despite Registrant's refusal to take
possession of the OSC, he is deemed to have been sufficiently served.
RFAA, at 6. The Government requests a final order holding that
Registrant has waived his opportunity for a hearing and otherwise
failed to respond to the Show Cause Order, and revoking Registrant's
DEA registration. Id. at 2.
Based on the DI's Declaration, the Government's written
representations, and my review of the record, I find that the
Government accomplished service of the OSC on Registrant on September
20, 2019. I find that the Government has satisfied its obligation under
the Due Process Clause ``to provide `notice reasonably calculated,
under all the circumstances, to apprise interested parties of the
pendency of the action and afford them an opportunity to present their
objections.''' Jones v. Flowers, 547 U.S. 220, 226 (2006) (quoting
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950)).
In this case, the Government tried to serve Registrant at his home and
his registered address--both of which were locations where the
Government reasonably believed Registrant would be located. RFAA, EX 8,
at 2-3. When those efforts failed, the DI contacted Registrant by
telephone and arranged an in-person meeting, during which the DI
explained to Registrant the context of the OSC. Id. at 3. Registrant
repeatedly refused to take possession of the OSC during this meeting,
even after its relevance had been clearly communicated to Registrant,
and the DI and SA made reasonable efforts to leave the papers with
Registrant. Id. Thus, Registrant was reasonably apprised of the
pendency of the action and his refusal to take possession of the papers
does not mean service was inadequate. See United States v Miller, 2007
WL 3173362 (E.D. Mich. Oct. 29, 2007) (The defendant of an institution
of an action against him ```cannot claim that the court has not [sic]
authority to act when he has willfully evaded the service of
process.''' (quoting Ali v. Mid-Atl. Settlement Servs., Inc., 233 FRD.
32, 36 (D.D.C. 2006) (citation omitted))).\1\
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\1\ See also Morgan v. United States, 304 U.S. 1, 18 (1938)
(``The right to a hearing embraces not only the right to present
evidence, but also a reasonable opportunity to know the claims of
the opposing party and to meet them. . . . Those who are brought
into contest with the Government in a quasijudicial proceeding aimed
at the control of their activities are entitled to be fairly advised
of what the Government proposes.'') (emphasis added).
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I also find that more than thirty days have now passed since the
Government accomplished service of the OSC. Further, based on the
Government's written representations, I find that neither Registrant,
nor anyone purporting to represent the Registrant, requested a hearing,
submitted a written statement while waiving Registrant's right to a
hearing, or submitted a corrective action plan. Accordingly, I find
that Registrant has waived the right to a hearing and the right to
submit a written statement and corrective action plan. 21 CFR
1301.43(d) and 21 U.S.C. 824(c)(2)(C). I, therefore, issue this
Decision and Order based on the record submitted by the Government,
which constitutes the entire record before me. 21 CFR 1301.43(e).
Findings of Fact
Registrant's DEA Registration
Registrant is the holder of DEA Certificate of Registration No.
FA7485027 at the registered address of 20905 Greenfield Rd., Ste. 702,
Southfield, Michigan. RFAA, EX 2 (Certification of Registration
History). Pursuant to this registration, Registrant is authorized to
dispense controlled substances in schedules II through V \2\ as
[[Page 5992]]
a practitioner.\3\ Registrant's registration expires on June 30, 2020,
and is ``in an active pending status.'' RFAA, EX 1 (Copy of
Registrant's Certificate of Registration).
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\2\ It is noted that the OSC mistakenly stated that Registrant
was a practitioner in ``Schedules II-IIIN.'' I find this to be
harmless error in that the Registration was appropriately identified
by its number and so the Registrant had adequate notice of the
registration subject to the proceeding.
\3\ Registrant is also authorized as a Data-Waiver practitioner
for up to 100 patients pursuant to 21 U.S.C. 823(g)(2)(a).
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The Status of Registrant's State License
On January 19, 2018, the Michigan Department of Licensing and
Regulatory Affairs ``executed an Order of Summary Suspension and an
Administrative Complaint charging [Registrant] with violating the
Public Health Code, [Mich. Comp. Laws] Sec. 333.1101 et seq.'' RFAA,
EX 3 (Final Order of the Board of Pharmacy Disciplinary Subcommittee,
Bureau of Professional Licensing, Michigan Department of Licensing and
Regulatory Affairs), at 1. On June 21, 2019, after an administrative
hearing, the Michigan Board of Pharmacy issued a Final Order revoking
Registrant's controlled substance license and drug control-location
licenses. Id. at 2, 4. The Final Order became effective thirty days
from its signature, on July 21, 2019. RFAA, EX 3, at 4.
According to Michigan's online records, of which I take official
notice,\4\ Registrant's controlled substance license and drug control-
location licenses remain revoked. https://aca3.accela.com/MILARA/GeneralProperty/PropertyLookUp.aspx (last visited January 3, 2020).
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\4\ Under the Administrative Procedure Act, an agency ``may take
official notice of facts at any stage in a proceeding--even in the
final decision.'' United States Department of Justice, Attorney
General's Manual on the Administrative Procedure Act 80 (1947) (Wm.
W. Gaunt & Sons, Inc., Reprint 1979). Pursuant to 5 U.S.C. 556(e),
``[w]hen an agency decision rests on official notice of a material
fact not appearing in the evidence in the record, a party is
entitled, on timely request, to an opportunity to show the
contrary.'' Accordingly, Registrant may dispute my finding by filing
a properly supported motion for reconsideration within 15 calendar
days of the date of this Order. Any such motion shall be filed with
the Office of the Administrator and a copy shall be served on the
Government. In the event Registrant files a motion, the Government
shall have 15 calendar days to file a response.
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Further, the Final Order states that reinstatement of Registrant's
revoked licenses ``is not automatic and shall be in accordance with
[Mich. Comp. Laws] Sec. Sec. 333.7315-333.7316.'' RFAA, EX 3, at 3. It
is noted that pursuant to Section 333.7315, Registrant may not apply
for reinstatement of his revoked licenses before the expiration of five
years after the effective date of revocation. Mich. Comp. Laws Sec.
333.7315.
Accordingly, I find that Registrant currently does not possess a
controlled substances license in Michigan, the State in which he is
registered with the DEA.
Discussion
Pursuant to 21 U.S.C. 824(a)(3), the Attorney General is authorized
to suspend or revoke a registration issued under section 823 of the
Controlled Substances Act (hereinafter, CSA), ``upon a finding that the
registrant . . . has had his State license or registration suspended .
. . [or] revoked . . . by competent State authority and is no longer
authorized by State law to engage in the . . . dispensing of controlled
substances.'' With respect to a practitioner, the DEA has also long
held that the possession of authority to dispense controlled substances
under the laws of the State in which a practitioner engages in
professional practice is a fundamental condition for obtaining and
maintaining a practitioner's registration. See, e.g., James L. Hooper,
M.D., 76 FR 71371 (2011), pet. for rev. denied, 481 Fed. Appx. 826 (4th
Cir. 2012); Frederick Marsh Blanton, M.D., 43 FR 27616, 27617 (1978).
This rule derives from the text of two provisions of the CSA.
First, Congress defined the term ``practitioner'' to mean ``a physician
. . . or other person licensed, registered, or otherwise permitted, by
. . . the jurisdiction in which he practices . . ., to distribute,
dispense, . . . [or] administer . . . a controlled substance in the
course of professional practice.'' 21 U.S.C. 802(21). Second, in
setting the requirements for obtaining a practitioner's registration,
Congress directed that ``[t]he Attorney General shall register
practitioners . . . if the applicant is authorized to dispense . . .
controlled substances under the laws of the State in which he
practices.'' 21 U.S.C. 823(f). Because Congress has clearly mandated
that a practitioner possess State authority in order to be deemed a
practitioner under the CSA, the DEA has held repeatedly that revocation
of a practitioner's registration is the appropriate sanction whenever
he is no longer authorized to dispense controlled substances under the
laws of the State in which he practices. See, e.g., James L. Hooper,
M.D., 76 FR at 71371-72; Sheran Arden Yeates, M.D., 71 FR 39130, 39131
(2006); Dominick A. Ricci, M.D., 58 FR 51104, 51105 (1993); Bobby
Watts, M.D., 53 FR 11919, 11920 (1988); Frederick Marsh Blanton, M.D.,
43 FR at 27617.
Under Michigan law, ``a person who manufactures, distributes,
prescribes, or dispenses a controlled substance in this state . . .
shall obtain a license issued by the administrator.'' Mich. Comp. Laws
Sec. 333.7303(1). Here, the undisputed evidence in the record is that
Registrant currently lacks authority to manufacture, distribute,
prescribe, or dispense controlled substances in Michigan. Thus, because
Registrant lacks authority to distribute, prescribe, or dispense
controlled substances in Michigan, Registrant is not eligible to
maintain a DEA registration. Accordingly, I will order that
Registrant's DEA registration be revoked.
Order
Pursuant to 28 CFR 0.100(b) and the authority vested in me by 21
U.S.C. 824(a), I hereby revoke DEA Certificate of Registration No.
FA7485027 issued to Solomon Adu-Beniako. This Order is effective March
4, 2020.
Dated: January 3, 2020.
Uttam Dhillon,
Acting Administrator.
[FR Doc. 2020-01971 Filed 1-31-20; 8:45 am]
BILLING CODE 4410-09-P