The amici argue that the government’s prosecution of Dr. Ruan, and physicians in similar cases, dangerously conflates medical error with criminal intent. They begin by situating the issue in the broader dual crises of untreated pain and rising opioid-related deaths, noting that while law enforcement is vital in combating illicit trafficking, its narrow enforcement lens is ill-suited to complex medical judgment. The brief contends that the government improperly uses the “standard of care” as a proxy for the Controlled Substances Act’s requirement that prescriptions be issued for a “legitimate medical purpose in the usual course of practice.” This approach, they argue, effectively strips away the statute’s mens rea requirement, turning cases of negligence or disagreement over medical practice into criminal liability and exposing physicians to wrongful conviction. Amici emphasize that under criminal law, intent must apply to all material elements, citing Liaparota and Flores-Figueroa to argue that the government must prove not just that a prescription was outside the standard of care, but that the physician knew at the time of writing that it was unlawful. They further maintain that a meaningful good faith defense, with both subjective and objective components, must be available to physicians who make honest, reasonable efforts to treat patients. Finally, amici warn of the broader harms to the health care system: fear of prosecution deters physicians from prescribing necessary medications, leaving patients in pain, driving some toward illicit and dangerous alternatives, and ultimately worsening both the opioid crisis and the undertreatment of pain. In their view, cases of mere error, negligence, or poor practice should be handled through civil or administrative channels, not criminal courts.

Summary

The amici curiae contend that governmental prosecution of physicians, such as in the case of Dr. Ruan, erroneously conflates medical errors with criminal intent. This argument arises within the broader context of widespread untreated pain and an increase in opioid-related deaths, noting that while law enforcement is crucial for combating illicit trafficking, its narrow focus is often ill-suited for evaluating complex medical judgments. A primary assertion is that the government improperly uses the "standard of care" as a substitute for the Controlled Substances Act's stipulation that prescriptions must be issued for a "legitimate medical purpose in the usual course of practice." This interpretative approach, it is argued, effectively nullifies the mens rea requirement of criminal intent, thereby transforming instances of professional negligence or disagreement over medical practice into criminal liability and exposing physicians to potential wrongful conviction. The amici emphasize that under criminal law, intent must apply to all material elements; consequently, the government must demonstrate not merely that a prescription was outside the standard of care, but that the physician knew it to be unlawful at the time of writing. Furthermore, a meaningful good faith defense, comprising both subjective and objective components, must be available to physicians who make honest and reasonable efforts to treat patients. Finally, the amici caution against the broader harms to the healthcare system, explaining that fear of prosecution deters physicians from prescribing necessary medications. This deterrence can leave patients in pain, potentially compelling them towards illicit and dangerous alternatives, ultimately worsening both the opioid crisis and the undertreatment of pain. Cases involving professional error, negligence, or suboptimal practice, they conclude, are more appropriately managed through civil or administrative channels rather than criminal courts.

Summary

Supporters of Dr. Ruan's case argue that the government's prosecution of physicians like him unfairly treats medical mistakes as criminal acts. They highlight that this issue occurs amidst two major problems: many people suffer from untreated pain, and opioid-related deaths are increasing. While law enforcement is important for stopping illegal drug trafficking, its focus is not suitable for handling complex medical decisions. The brief claims that the government incorrectly uses the idea of "standard of care" as a substitute for the Controlled Substances Act's rule that prescriptions must be for a "legitimate medical purpose in the usual course of practice." This approach, they contend, removes the legal requirement to prove criminal intent, turning cases of simple error or differing medical opinions into criminal offenses and making physicians vulnerable to wrongful convictions.

The advocates stress that in criminal law, intent must relate to every key part of the crime. They argue the government must show not only that a prescription was outside the standard of care but also that the physician knew it was unlawful when written. Furthermore, they believe physicians must have a meaningful "good faith" defense, considering both the doctor's honest belief and what a reasonable person would have done. Finally, the supporters warn of wider negative effects on healthcare: the fear of prosecution discourages doctors from prescribing necessary pain medication, leaving patients in pain, pushing some toward illegal and dangerous alternatives, and ultimately worsening both the opioid crisis and the problem of undertreated pain. They conclude that cases involving mere error, negligence, or poor practice should be handled through non-criminal legal or administrative processes, not criminal courts.

Summary

Groups supporting Dr. Ruan argue that the government wrongly treats medical errors as criminal acts when prosecuting doctors in cases like his. They point out two major problems: many adults suffer from untreated pain, and opioid-related deaths continue to rise. While law enforcement is crucial for stopping illegal drug dealing, these groups believe its approach is not suitable for complex medical decisions.

The core of their argument is that the government incorrectly uses a doctor's "standard of care" (what a typical doctor would do) as proof that a prescription was not for a "legitimate medical purpose," which the Controlled Substances Act requires. This method, they claim, removes the need for prosecutors to prove that a doctor intended to break the law. Instead, it can turn honest mistakes or differing medical opinions into criminal charges, potentially leading to doctors being wrongly convicted.

They emphasize that criminal law requires proof of intent for every key part of a crime. Therefore, the government should have to show that a doctor knew a prescription was illegal when it was written, not just that it did not meet the usual standard of care. These groups also believe doctors must have a strong "good faith defense," meaning they should be protected if they made honest, reasonable efforts to treat patients.

Finally, they warn about the wider damage to the healthcare system. The fear of being prosecuted discourages doctors from prescribing needed medications, leaving patients in pain. Some patients may then seek dangerous, illegal alternatives, worsening both the opioid crisis and the problem of untreated pain. These groups conclude that simple errors, negligence, or poor medical practice should be handled through civil lawsuits or medical board reviews, not by criminal courts.

Summary

A group of supporters argues that the government is confusing medical mistakes with criminal acts in cases involving doctors, such as Dr. Ruan. They point to two big problems: many people suffer from pain, and too many people die from opioid-related issues. While police are important for stopping illegal drug sales, their methods are not right for handling complex medical decisions made by doctors.

The group claims the government wrongly uses the idea of "standard of care" (what good doctors usually do) instead of proving that a prescription was for a "real medical reason," as the law requires. This way of thinking removes the need to prove a doctor intended to do something wrong. It turns simple mistakes or disagreements about medical practice into criminal offenses, which could lead to doctors being wrongly found guilty.

In criminal cases, the law usually requires proof that a person meant to do wrong for every important part of the crime. So, the government should have to show that a doctor knew a prescription was against the law when writing it. Doctors should also be allowed to argue that they acted in "good faith," meaning they made honest and reasonable efforts to treat their patients.

The group also warns about larger problems for healthcare. If doctors are afraid of being put in jail, they might not prescribe needed medicines, leaving patients in pain. Some patients might then seek out dangerous, illegal drugs, making both the opioid problem and the issue of untreated pain worse. They believe that simple medical mistakes or poor practices should be handled by civil courts or medical boards, not by criminal courts.