Notice2025-13313
Sasha Melissa Ikramelahai; Decision and Order
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Published
July 16, 2025
Issuing agencies
Justice DepartmentDrug Enforcement Administration
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<title>Federal Register, Volume 90 Issue 134 (Wednesday, July 16, 2025)</title>
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[Federal Register Volume 90, Number 134 (Wednesday, July 16, 2025)]
[Notices]
[Pages 32017-32021]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-13313]
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DEPARTMENT OF JUSTICE
Drug Enforcement Administration
Sasha Melissa Ikramelahai; Decision and Order
On January 22, 2025, the Drug Enforcement Administration (DEA or
Government) issued an Order to Show Cause (OSC) to Sasha Melissa
Ikramelahai of Southern Pines, North Carolina (Registrant). Request for
Final Agency Action (RFAA), Exhibit (RFAAX) 1, at 1, 5. The OSC
proposed the revocation of Registrant's DEA registration, No.
MI8411061, alleging that she currently lacks state authority to handle
controlled substances in North Carolina and that she materially
falsified her application for registration. Id. (citing 21 U.S.C.
824(a)(1), 824(a)(3)).
On March 27, 2025, the Government submitted an RFAA to the
Administrator requesting that the Agency issue a default final order
revoking Registrant's registration. RFAA, at 1, 3, 6-7. After carefully
reviewing the entire record and conducting the analysis as set forth in
detail below, the Agency finds that Registrant is in default, finds
that Registrant is without state authority, and finds that Registrant
materially falsified her application. Accordingly, the Agency grants
the Government's RFAA and revokes Registrant's registration.
I. Default Determination
Under 21 CFR 1301.43, a registrant entitled to a hearing who fails
to file a timely hearing request ``within 30 days after the date of
receipt of the [OSC] . . . shall be deemed to have waived their right
to a hearing and to be in default'' unless ``good cause'' is
established for the failure. 21 CFR 1301.43(a), (c)(1). In the absence
of a demonstration of good cause, a registrant who fails to timely file
an answer also is ``deemed to have waived their right to a hearing and
to be in default.'' 21 CFR 1301.43(c)(2). Unless excused, a default
constitutes ``an admission of the factual allegations of the [OSC].''
21 CFR 1301.43(e).
The OSC notified Registrant of her right to file a written request
for hearing and answer, and that if she failed to file such a request
and answer, she would be deemed to have waived her right to a hearing
and be in default.\1\ RFAAX 1,
[[Page 32018]]
at 3-4 (citing 21 CFR 1301.43). Here, Registrant did not request a
hearing, file an answer, or respond to the OSC in any way. RFAA, at 1-
2, 6. Accordingly, Registrant is in default. 21 CFR 1301.43(c)(1);
RFAA, at 1, 3, 6.
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\1\ Based on the Government's submissions in its RFAA dated
March 27, 2025, the Agency finds that service of the OSC on
Registrant was adequate. Specifically, the Declaration from a DEA
Diversion Investigator (DI) indicates that on January 24, 2025, DIs
attempted to serve the OSC on Registrant at her home address. RFAAX
2, at 1. The DIs were met by Registrant's mother, who told them that
Registrant did not live at that address. Id. On January 27, 2025, DI
attempted to serve the OSC to several email addresses associated
with Registrant. Id. at 2. Service by email was successful as DI
received an email delivery receipt from Registrant's registered
email address. Id. Additionally, on February 6, 2025, DI attempted
to serve the OSC on Registrant by USPS Certified Mail at her
registered address, but the mail was returned to sender. Id. On
February 7, 2025, DI attempted to reach Registrant by phone at her
registered employer, but was told by the clinic's CEO that she no
longer worked there. Id. Based on these multiple attempts at service
that were ``reasonably calculated'' to notify her of the OSC, and
the fact that DI received an email delivery receipt from
Registrant's registered email address, the Agency finds that due
process notice requirements have been satisfied. See Jones v.
Flowers, 547 U.S. 220, 226 (2006) (quoting Mullane v. Cent. Hanover
Bank & Trust Co., 339 U.S. 306, 314 (1950)); Mohammed S. Aljanaby,
M.D., 82 FR 34,552, 34,552 (2017) (finding that service by email
satisfies due process where the email is not returned as
undeliverable and other methods have been unsuccessful); Emilio
Luna, M.D., 77 FR 4,829, 4,830 (2012) (concluding that ``the use of
email to serve Registrant satisfied due process because service was
made to an email address which Registrant provided to the Agency and
the Government did not receive back either an error or undeliverable
message'').
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``A default, unless excused, shall be deemed to constitute a waiver
of the [registrant's] right to a hearing and an admission of the
factual allegations of the [OSC].'' 21 CFR 1301.43(e). Because
Registrant is in default and has not moved to excuse the default, the
Agency finds that Registrant has admitted to the factual allegations in
the OSC. 21 CFR 1301.43(c)(1), (e), (f)(1).
Further, ``[i]n the event that [a registrant] . . . is deemed to be
in default . . . DEA may then file a request for final agency action
with the Administrator, along with a record to support its request. In
such circumstances, the Administrator may enter a default final order
pursuant to [21 CFR] 1316.67.'' 21 CFR 1301.43(f)(1). Here, the
Government has requested final agency action based on Registrant's
default pursuant to 21 CFR 1301.43(c), (f), and 1301.46. RFAA, at 1, 3,
6; see also 21 CFR 1316.67.
II. Lack of State Authority
A. Findings of Fact
The Agency finds that, in light of Registrant's default, the
factual allegations in the OSC are deemed admitted. 21 CFR 1301.43(e).
Accordingly, Registrant is deemed to have admitted, in accordance with
the OSC, that on July 9, 2024, the North Carolina Medical Board (NCMB)
annulled Registrant's physician assistant license. RFAAX 1, at 3.
Specifically, the NCMB annulled Registrant's physician assistant
license based on findings that (a) she engaged in immoral or
dishonorable conduct; (b) made false statements or representations to
the NCMB; (c) engaged in unprofessional conduct by fraudulently
obtaining and using the identity, credentials, experience, and
licensing information of someone else in false representations and
forged documents; and (d) obtained or attempted to obtain a practice,
money, or anything of value by false representations. Id.
According to North Carolina online records, of which the Agency
takes official notice, Registrant's physician assistant license is in
an ``Inactive'' status.\2\ North Carolina Medical Board License
Verification Search, <a href="https://portal.ncmedboard.org/verification/search.aspx">https://portal.ncmedboard.org/verification/search.aspx</a> (last visited date of signature of this Order).
Accordingly, the Agency finds that Registrant is not licensed as a
physician assistant in North Carolina, the state in which she is
registered with DEA.\3\
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\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).
\3\ 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.'' The material fact here is
that Registrant, as of the date of this Decision and Order, is not
licensed to practice as a physician assistant in North Carolina.
Accordingly, Registrant may dispute the Agency's finding by filing a
properly supported motion for reconsideration of findings of fact
within fifteen calendar days of the date of this Order. Any such
motion and response shall be filed and served by email to the other
party and to the DEA Office of the Administrator, Drug Enforcement
Administration, at <a href="/cdn-cgi/l/email-protection#187c7d7936797c7c7736796c6c776a767d616b587c7d79367f776e"><span class="__cf_email__" data-cfemail="d7b3b2b6f9b6b3b3b8f9b6a3a3b8a5b9b2aea497b3b2b6f9b0b8a1">[email protected]</span></a>.
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B. Discussion
Pursuant to 21 U.S.C. 824(a)(3), the Attorney General may suspend
or revoke a registration issued under 21 U.S.C. 823 ``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, 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. Gonzales v. Oregon, 546 U.S.
243, 270 (2006) (``The Attorney General can register a physician to
dispense controlled substances `if the applicant is authorized to
dispense . . . controlled substances under the laws of the State in
which he practices.' . . . The very definition of a `practitioner'
eligible to prescribe includes physicians `licensed, registered, or
otherwise permitted, by the United States or the jurisdiction in which
he practices' to dispense controlled substances. [21 U.S.C.]
802(21).''). The Agency has applied these principles consistently. See,
e.g., James L. Hooper, M.D., 76 FR 71,371, 71,372 (2011), pet. for rev.
denied, 481 F. App'x 826 (4th Cir. 2012); Frederick Marsh Blanton,
M.D., 43 FR 27,616, 27,617 (1978).\4\
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\4\ This rule derives from the text of two provisions of the
Controlled Substances Act (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(g)(1). Because Congress has clearly mandated that a
practitioner possess state authority in order to be deemed a
practitioner under the CSA, 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, 76 FR at 71,371-72; Sheran Arden Yeats, M.D., 71 FR
39,130, 39,131 (2006); Dominick A. Ricci, M.D., 58 FR 51,104, 51,105
(1993); Bobby Watts, M.D., 53 FR 11,919, 11,920 (1988); Blanton, 43
FR at 27,617.
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According to North Carolina statute, ``dispense'' means ``to
deliver a controlled substance to an ultimate user or research subject
by or pursuant to the lawful order of a practitioner, including the
prescribing, administering, packaging, labeling, or compounding
necessary to prepare the substance for that delivery.'' N.C. Gen. Stat.
Ann. Sec. 90-87(8) (West 2025). Further, a ``practitioner'' means a
``physician . . . or other person licensed, registered or otherwise
permitted to distribute, dispense, conduct research with respect to or
to administer a controlled substance so long as such activity is within
the normal course of professional practice or research in this State.''
Id. at Sec. 90-87(22)(a).
Here, the undisputed evidence in the record is that Registrant
lacks authority to practice as a physician assistant in North Carolina.
As discussed above, an individual must be a licensed practitioner to
dispense a controlled substance in North Carolina. Thus, because
Registrant lacks authority to
[[Page 32019]]
practice as a physician assistant in North Carolina and, therefore, is
not authorized to handle controlled substances in North Carolina,
Registrant is not eligible to maintain a DEA registration in that
state. Accordingly, the Agency will order that Registrant's DEA
registration be revoked.
III. Material Falsification
A. Findings of Fact
The Agency finds that, in light of Registrant's default, the
factual allegations in the OSC are deemed admitted. 21 CFR 1301.43(e).
Accordingly, Registrant is deemed to have admitted to each of the
following facts. On October 27, 2023, Registrant applied for DEA
registration as a mid-level practitioner, physician assistant, in
Schedules II through V. RFAAX 1, at 2. On October 30, 2023, Registrant
was granted DEA registration No. MI8411061. Id.
Prior to applying for DEA registration, Registrant fraudulently
used the identity and credentials of another physician assistant to
obtain her own North Carolina physician assistant license. Id. Her
North Carolina physician assistant license, which she obtained by
fraud, was used as a basis for establishing the required state
authority to procure her DEA registration. Id. at 2-3.
When Registrant applied for DEA registration, the application
requested information regarding the medical/professional school that
she attended and the year she graduated. Id. at 2. Registrant responded
by stating that she graduated in 2014 from the University of New
Mexico, facts that were true of the other physician assistant whose
identity Registrant had assumed, but not of Registrant. Id.
The application also asked: ``Have you graduated, in good standing,
from an accredited school of . . . physician assistant . . . in the
United States during the 5-year period immediately preceding the date
on which you first submitted a registration or renewal and the
curriculum included not less than 8 hours of training?'' Id. Registrant
answered ``yes'' to this question. Id.
By signing the application for registration, Registrant represented
that the following statement contained on the DEA application was true
in regards to her state authority to practice as a physician assistant
in North Carolina: ``You must be currently authorized to prescribe,
distribute, dispense, conduct research, or otherwise handle the
controlled substances in the schedules for which you are applying under
the laws of the state or jurisdiction in which you are operating or
propose to operate.'' Id. at 3.
B. Discussion
A DEA registration may be denied, suspended, or revoked upon a
finding that the applicant or registrant materially falsified any
application filed pursuant to or required by the Controlled Substances
Act (CSA). 21 U.S.C. 824(a)(1).\5\ To present a prima facie case for
material falsification, the Government's record evidence must show (1)
the submission of an application, (2) containing a false statement and/
or omitting information that the application requires, (3) when the
submitter knew or should have known that the statement is false and/or
that the omitted information existed and the application required its
disclosure, and (4) the false statement and/or required but omitted
information is material, that is, it ``connect[s] to at least one of
[the section 823] factors that, according to the CSA, [the
Administrator] `shall' consider'' when analyzing ``whether issuing a
registration `would be inconsistent with the public interest.''' Frank
Joseph Stirlacci, M.D., 85 FR 45,229, 45,238 (2020) (citing 21 U.S.C.
823 and Kungys, 485 U.S. at 771). The Government must establish
material falsification with record evidence that is clear, unequivocal,
and convincing. Kungys, 485 U.S. at 772; Stirlacci, 85 FR at 45,230-39.
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\5\ A statutory basis to deny an application pursuant to section
823 is also a basis to revoke or suspend a registration pursuant to
section 824, and vice versa, because doing ``otherwise would mean
that all applications would have to be granted only to be revoked
the next day . . . .'' Robert Wayne Locklear, M.D., 86 FR 33,738,
33,744-45 (2021) (collecting cases).
The Supreme Court's decision in Kungys v. United States, 485
U.S. 759 (1988), and its progeny, guide the Agency's implementation
of these CSA provisions.
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First, the Government must prove that the applicant or registrant
submitted an application for registration pursuant to the CSA. 21
U.S.C. 824(a)(1); see also 21 U.S.C. 822 (persons required to
register); 21 U.S.C. 823(g)(1) (registration requirements).
Second, the Government must prove that the application contained a
false statement or omitted information that the application required,
either of which may constitute a material falsity. See, e.g., Emed
Medical Company LLC and Med Assist Pharmacy, 88 FR 21,719, 21,720
(2023) (applicant falsely answered ``no'' to Liability Question 3 on
seventeen applications when the true answer was ``yes''); Richard J.
Settles, D.O., 81 FR 64,940, 64,945-46 (2016) (applicant failed to
disclose an interim consent agreement restricting his license based on
findings that he issued controlled substance prescriptions without
federal or state legal authority to do so). In making this assessment,
the Agency will examine the entire application, including registrant's
``yes/no'' answers to the liability questions and any follow-up
response(s). Daniel A. Glick, D.D.S., 80 FR 74,800, 74,802, 74,808-09
(2015). To establish an omission, the Government must show both that
omitted information existed and that the application required inclusion
of that information. See, e.g., Richard A. Herbert, M.D., 76 FR 53,942,
53,956 (2011) (omission of a probation which the application required
to be identified); Michel P. Toret, M.D., 82 FR 60,041, 60,042 (2017)
(Voluntary Surrender Form alone is insufficient evidence to find
material falsification based on registrant's ``no'' answer to the
question regarding ``surrender[s] (for cause)'').
Third, the Government must prove that the applicant or registrant
knew or should have known that the statement is false and/or that the
omitted information existed and the application required its
disclosure. See John J. Cienki, M.D., 63 FR 52,293, 52,295 (1998)
(``[I]n finding that there has been a material falsification of an
application, it must be determined that the applicant knew or should
have known that the response given to the liability question was
false.''); Samuel Arnold, D.D.S., 63 FR 8,687, 8,688 (1998) (``It is
also undisputed that Respondent knew that his Ohio dental license had
previously been suspended.''); Bobby Watts, M.D., 58 FR 46,995, 46,995
(1993) (``Respondent knew that the Tennessee Board of Medical Examiners
had suspended his medical license on May 7, 1987, and had placed his
state medical license on probation on May 2, 1988.''); see also
Stirlacci, 85 FR at 45,236-37 & nn.22-23 (collecting cases).
Fourth, the Government must prove that the false statement and/or
required but omitted information is ``material.'' Kungys holds that a
statement is material if it is ``predictably capable of affecting,
i.e., had a natural tendency to affect, the [Agency's] official
decision,'' or stated differently, ``had a natural tendency to
influence the decision.'' Kungys, 485 U.S. at 771-72. As already
discussed, materiality, for the purposes of the CSA, is tied to the
factors that the Administrator ``shall'' consider when determining
whether issuance of a registration ``would be inconsistent with the
public interest.'' 21 U.S.C. 823; Kungys, 485 U.S. at 771-72;
Stirlacci, 85 FR at 45,234, 45,238.
[[Page 32020]]
The Government has the burden of proof in this proceeding. 21 CFR
1301.44. After evaluating each of the alleged material falsifications,
the Agency finds that the Government's record evidence presents a prima
facie case that Registrant submitted a materially false application. 21
U.S.C. 823, 824(a)(1).
Here, there is no question that Registrant submitted an application
for DEA registration and that the application contained multiple
falsities. RFAAX 1, at 2-3. Two such falsities were that Registrant,
assuming the identity of a properly licensed practitioner, represented
that she attended the University of New Mexico for professional school
and graduated in 2014. Id. at 2. Registrant, through her signature,
also represented that she was ``currently authorized to prescribe,
distribute, dispense, conduct research, or otherwise handle the
controlled substances in the schedules for which [she was] applying
under the laws of the state or jurisdiction in which [she was]
operating or propos[ed] to operate.'' Id. at 3.
But Registrant's state authorization to handle controlled
substances was not obtained pursuant to law--it was obtained by fraud.
Registrant, in assuming someone else's identity, certainly knew or
should have known that she had not graduated from the University of New
Mexico in 2014 as she represented to the NCMB and to DEA. Indeed, the
NCMB later found that Registrant's state physician assistant license
had been acquired under false pretenses as a result of Registrant
representing herself as someone else. Id. Accordingly, the NCMB
annulled the license it had issued to Registrant under false pretenses.
Id. Thus, Registrant falsified her DEA application by representing that
she was authorized to handle controlled substances ``under the laws
of'' North Carolina when she would not have been granted state
authority were it not for her fraud. Id.
In addition, the falsification was material. The Agency has
consistently held for decades that possessing valid state authority to
handle controlled substances is a prerequisite for obtaining a DEA
registration.\6\ Thus, whether an applicant possesses valid state
authority to handle controlled substances in the state for which the
applicant seeks registration is a critical factor DEA must consider
when reviewing an application.\7\
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\6\ See Joely Keen, A.P.R.N., 90 FR 13,882, 13,883 (2025) (``DEA
has . . . 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.''); Blanton, 43 FR at 27,617 (holding that ``[s]tate
authorization to dispense or otherwise handle controlled substances
is a prerequisite to'' obtaining and maintaining a DEA
registration).
\7\ See 21 U.S.C. 802(21) (defining a ``practitioner'' as one
who is ``licensed, registered, or otherwise permitted, by . . . the
jurisdiction in which he practices'' to handle controlled substances
``in the course of professional practice''); 21 U.S.C. 823(g)(1)
(``The 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.
824(a)(3) (providing a basis for revoking a registration where the
registrant lacks the requisite state authority to dispense
controlled substances); Gonzales v. Oregon, 546 U.S. 243, 270 (2006)
(``The structure and operation of the CSA presume and rely upon a
functioning medical profession regulated under the States' police
powers'' and explaining registration requirements and the definition
of ``practitioner''); Hatem M. Ataya, M.D., 81 FR 8,221, 8,244
(2016) (explaining ``the possession of state authority is a
prerequisite for obtaining a registration''); Hoi Y. Kam, M.D., 78
FR 62,694, 62,696 (2013) (``Because possessing authority to dispense
controlled substances under the laws of the State in which a
physician practices medicine is a requirement for holding a DEA
registration, . . . a false answer to the state license question is
material where an applicant no longer holds authority to practice
medicine (regardless of the reason for the State's action) or
authority to dispense controlled substances . . . .'') (emphasis
added).
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In Steven Bernhard, D.O., the Agency found that an application was
materially false where the applicant falsely represented that he
possessed valid state authority to handle controlled substances, when
in fact, he did not. 82 FR 23,298, 23,300 (2017). The Agency explained
that ``[b]ecause the possession of state authority is a prerequisite to
obtaining and maintaining a practitioner's registration, Respondent's
false representations that he currently possessed a state license . . .
[was] capable of influencing the Agency's decision to grant his . . .
application.'' Id.; see also Thomas G. Easter II, M.D., 69 FR 5,579,
5,580 (2004) (finding that applicant materially falsified an
application for registration by falsely representing that ``he was
`currently authorized to prescribe' controlled substances `under the
laws of the State or jurisdiction in which [he was] operating or
propos[ed] to operate' '').
Thus, Registrant's application representing that she possessed
state authorization obtained pursuant to law to handle controlled
substances directly affected the statutory analysis that DEA was
required to make when it reviewed Registrant's application. 21 U.S.C.
802(21), 823(g)(1), 824(a)(3); Gonzales, 546 U.S. at 270; Stirlacci, 85
FR at 45,238; Bernhard, 82 FR at 23,300; Easter, 69 FR at 5,580. Stated
differently, Registrant's application led DEA to believe that she
possessed valid state authority when, in fact, that state authority was
invalid under state law as it had been obtained by fraud. RFAAX 1, at
2-3; Bernhard, 82 FR at 23,300; Easter, 69 FR at 5,580. Thus, her false
representation was material because it was ``predictably capable of
affecting . . . [DEA's] official decision'' regarding whether
Registrant met ``the requirements for'' registration. Kungys, 485 U.S.
at 771.
In sum, the Agency finds clear, unequivocal, and convincing record
evidence, and Registrant is deemed to have admitted, that she submitted
a materially false application for registration. 21 U.S.C. 824(a)(1);
21 CFR 1301.43(e).
As a result of this established violation, the Agency finds that
the Government has established a prima facie case for sanction, that
Registrant did not rebut that prima facie case, and that there is
substantial record evidence supporting the revocation of Registrant's
registration. 21 U.S.C. 824(a)(1).
C. Sanction
Where, as here, the Government has presented a prima facie case
showing that a registrant submitted a materially false application for
registration, the burden shifts to Registrant to show why she can be
trusted with a registration. Morall v. Drug Enf't Admin., 412 F.3d 165,
181 (D.C. Cir. 2005); Jones Total Health Care Pharmacy, LLC v. Drug
Enf't Admin., 881 F.3d 823, 830 (11th Cir. 2018); Garrett Howard Smith,
M.D., 83 FR 18,882, 18,904 (2018). The issue of trust is a fact-
dependent determination based on the circumstances presented by the
individual practitioner. Jeffrey Stein, M.D., 84 FR 46,968, 46,972
(2019); see also Jones Total Health Care Pharmacy, 881 F.3d at 833.
Historically, the Agency has considered acceptance of responsibility,
egregiousness, and deterrence when making this assessment.
Specifically, the Agency requires the practitioner to accept
responsibility for his or her violation. Jones Total Health Care
Pharmacy, 881 F.3d at 833; ALRA Labs, Inc. v. Drug Enf't Admin., 54
F.3d 450, 452 (7th Cir. 1995). Acceptance of responsibility must be
unequivocal. Janet S. Pettyjohn, D.O., 89 FR 82,639, 82,641 (2024);
Mohammed Asgar, M.D., 83 FR 29,569, 29,573 (2018); see also Jones Total
Health Care Pharmacy, 881 F.3d at 830-31.
In addition, the Agency considers the egregiousness and extent of
the misconduct in determining the appropriate sanction. Jones Total
Health Care Pharmacy, 881 F.3d at 834 & n.4. The Agency also considers
the need to deter similar acts by Registrant and by
[[Page 32021]]
future applicants for registration. Stein, 84 FR at 46,972-73.
Here, Registrant did not timely request a hearing, or timely or
properly answer the allegations, and was therefore deemed to be in
default. 21 CFR 1301.43(c)(1), (e), (f)(1); RFAA, at 1-4. To date,
Registrant has not filed a motion with the Office of the Administrator
to excuse the default. 21 CFR 1301.43(c)(1). Registrant has thus failed
to answer the allegations contained in the OSC and has not otherwise
availed herself of the opportunity to refute the Government's case. As
such, Registrant has not accepted responsibility for the proven
violations, has made no representations regarding her future compliance
with the CSA, and has not made any demonstration that she can be
trusted with registration.
Moreover, the evidence presented by the Government shows that
Registrant misrepresented her qualifications for registration and used
another person's identity in order to fraudulently obtain a state
professional license, further demonstrating that Registrant cannot be
trusted with the responsibilities of holding a controlled substances
registration. To permit Registrant to maintain a registration under
these circumstances would send a dangerous message that identity theft
and fraud are acceptable means of acquiring a DEA registration and that
DEA does not require truthfulness from applicants and registrants.
Accordingly, the Agency will order the revocation of Registrant's
registration.\8\
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\8\ In this matter there are two separate and distinct grounds
by which the Government proposed revocation, Registrant's lack of
state authority and her material falsification; each ground,
standing alone, supports the Agency's decision to revoke.
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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.
MI8411061 issued to Sasha Melissa Ikramelahai. Further, pursuant to 28
CFR 0.100(b) and the authority vested in me by 21 U.S.C. 823(g)(1), I
hereby deny any pending applications of Sasha Melissa Ikramelahai to
renew or modify this registration, as well as any other pending
application of Sasha Melissa Ikramelahai for additional registration in
North Carolina. This Order is effective August 15, 2025.
Signing Authority
This document of the Drug Enforcement Administration was signed on
July 10, 2025, by Acting Administrator Robert J. Murphy. That document
with the original signature and date is maintained by DEA. For
administrative purposes only, and in compliance with requirements of
the Office of the Federal Register, the undersigned DEA Federal
Register Liaison Officer has been authorized to sign and submit the
document in electronic format for publication, as an official document
of DEA. This administrative process in no way alters the legal effect
of this document upon publication in the Federal Register.
Heather Achbach,
Federal Register Liaison Officer, Drug Enforcement Administration.
[FR Doc. 2025-13313 Filed 7-15-25; 8:45 am]
BILLING CODE 4410-09-P
</pre><script data-cfasync="false" src="/cdn-cgi/scripts/5c5dd728/cloudflare-static/email-decode.min.js"></script></body>
</html>Indexed from Federal Register on July 16, 2025.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.