Gonzalez-Droz v. Gonzalez-Colon
Until 2005, when the Puerto Rico Board of Medical Examiners promulgated a first-in-the-nation regulation that limited the practice of cosmetic medicine to particular classes of medical specialists, all licensed physicians in Puerto Rico could perform cosmetic surgery. The Board enforced the regulation against a physician who did not possess the required specialty board certification. The district court disposed of challenges on the ground that the defendants enjoyed various kinds of immunity and did not reach constitutional issues. The First Circuit affirmed, rejecting claims that the suspension of plaintiff's license amounted to a substantive due process violation and was retaliation for past testimony. The Board afforded due process protections in its hearing process.