STATE COURT CASES
01-2-9952 Elias v. Educational Commission for Foreign Medical Graduates,App. Div. (per curiam) (10 pp.) Plaintiff appeals from the order granting summary judgment to defendant Educational Commission for Foreign Medical Graduates (ECFMG) and dismissing his complaint with prejudice. Plaintiff attended the Universidad Autonoma de Guadalajara Medical School (UAGMS) in Mexico from 1987 to 1991. ECFMG rejected his application to take Step 1 of the U.S. Medical Licensing Examination because he had not produced a copy of a final medical diploma. There is no evidence that plaintiff reapplied with the necessary documentation. Instead, he filed a complaint alleging that ECFMG and the New Jersey State Board of Medical Examiners had arbitrarily and capriciously denied him the opportunity to take Step 1 in violation of his procedural and substantive due process and equal protection rights. The appellate panel affirms the trial court’s decision granting ECFMG’s motion for summary judgment, finding plaintiff failed to establish state action or that ECFMG illegally delegated its authority to UAGMS.
