The stipulation further provided that the California Board would deem as admitted one set of allegations against Tatreau if he ever applied for renewal or reinstatement of his certificate in California. In Colorado, as in California, Tatreau agreed to surrender his medical license. It is undisputed that the Minnesota Board's disciplinary action against Tatreau deprived him of a property interest in his medical license. See Humenansky v. Tatreau claims that the board's proceedings depriving him of that interest violated due process.
Due process requires notice and an opportunity to be heard.
Tatreau does not argue that he received inadequate notice, but claims that he was not given an adequate opportunity to be heard. The Minnesota Board was not required to provide Tatreau with a hearing on the underlying allegations made against him in California and Colorado, because he expressly waived his right to a hearing on those allegations. Neither did the lack of a full evidentiary hearing on the subject of mitigating factors violate due process. Tatreau was given the opportunity to submit a memorandum and a supporting affidavit in opposition to the Complaint Review Committee's motion for summary disposition, to participate in a prehearing conference with the ALJ, and to argue orally before the board. These proceedings satisfied minimum due process requirements under the circumstances.