v. Colorado Medical Board

Summary

The court held that the physician could not invalidate the Colorado Medical Board’s investigative subpoena merely by challenging the referring agency’s policy under the Open Meetings Law or the Administrative Procedure Act. The referring agency was not subject to the Open Meetings Law as a state agency and did not violate the Administrative Procedure Act in adopting or applying the policy. Independently, the subpoena served a lawful purpose because it was authorized by the Board’s statutory duty to investigate suspected unprofessional conduct and was properly tailored to that investigation.