Lucas v. Ohio State Dental Bd.

Citations

• 254 N.E.3d 830
• 2024 Ohio 4986

Syllabus

ADMINISTRATIVE APPEAL — REVIEW OF SANCTION — DENTAL LICENSE SUSPENSION — CAUSATION — ABUSE OF DISCRETION: The trial court did not abuse its discretion in affirming the Ohio State Dental Board's order suspending appellant-dentist's dental license and increasing the sanction recommended by the hearing examiner even though one of the agency's reasons for increasing the penalty based on the outcome of the dental surgery could only be interpreted as referring to the death of the appellant's patient and there was no evidence in the record establishing a causal connection between the patient's death and appellant's violation of the standard of care, because appellant failed to challenge the agency's separate and independent basis for increasing the sanction and was therefore unable to demonstrate error as courts must defer to an agency's sanction provided that sanction is supported by reliable, probative, and substantial evidence.