The Drug Enforcement Administration has revoked the Certificate of Registration for Abolghasem Rezaei, a physician in Lawton, Oklahoma, following the suspension and inactivation of his state license to handle controlled substances. This decision, detailed in a Federal Register notice published on October 20, 2025, underscores the federal requirement that medical practitioners must hold valid state authority to maintain DEA registration. Issued under 21 U.S.C. 824(a)(3), the revocation took effect on November 19, 2025, after Rezaei failed to contest an Order to Show Cause. The case illustrates the interplay between state and federal oversight in regulating controlled substances, potentially affecting patient care and professional practices in Oklahoma.
Background of the Case
The proceedings began when the DEA issued an Order to Show Cause to Rezaei on May 22, 2025, proposing to revoke his Certificate of Registration No. FR0228747. The order alleged that Rezaei lacked authority to handle controlled substances in Oklahoma, the state where he is registered with the DEA. This stemmed from actions by the Oklahoma State Bureau of Narcotics and Dangerous Drugs Control, which suspended Rezaei's state registration on December 5, 2024. That suspension was upheld on February 13, 2025, and as of the DEA's decision, his Oklahoma registration remains inactive, according to state records.
Rezaei was personally served with the Order to Show Cause on June 11, 2025, as documented in a DEA Form-12 signed by him. The order informed him of his right to request a hearing within 30 days, but he did not do so, leading to a default under 21 CFR 1301.43. In default cases, the factual allegations in the order are deemed admitted, and the DEA may proceed to a final agency action without a hearing. The government submitted a Request for Final Agency Action on July 28, 2025, which the DEA Administrator approved, resulting in the revocation.
This case fits into a broader pattern of DEA enforcement actions where state-level disciplinary measures trigger federal consequences. Oklahoma's Uniform Controlled Dangerous Substances Act requires registration with the OBNDD for anyone handling controlled substances, with limited exceptions that do not apply here.
Legal Basis for Revocation
Federal law authorizes the Attorney General, delegated to the DEA Administrator, to revoke a registration if a practitioner has had their state license or registration suspended or revoked and is no longer authorized to dispense controlled substances. This is outlined in 21 U.S.C. 824(a)(3). The Controlled Substances Act defines a practitioner as someone licensed or permitted by their state to handle controlled substances in professional practice, per 21 U.S.C. 802(21) and 823(g)(1).
DEA precedents consistently uphold this principle. For instance, in James L. Hooper, M.D. (76 FR 71371, 2011), the agency revoked a registration after state authority was lost, a decision affirmed by the Fourth Circuit Court of Appeals. Similarly, Frederick Marsh Blanton, M.D. (43 FR 27616, 1978) established that state authorization is a fundamental condition for DEA registration. The U.S. Supreme Court in Gonzales v. Oregon (546 U.S. 243, 2006) reinforced that federal registration depends on state licensure.
In Rezaei's case, the DEA took official notice of Oklahoma's online records confirming his inactive status, allowing for potential rebuttal under the Administrative Procedure Act (5 U.S.C. 556(e)). Without such rebuttal, the facts stood unchallenged.
Key Players and Procedural Details
Abolghasem Rezaei, the registrant, is a medical doctor based in Lawton, Oklahoma. The primary state authority involved is the Oklahoma Bureau of Narcotics and Dangerous Drugs Control, responsible for regulating controlled substances under state law. The DEA, part of the Department of Justice, handled the federal action, with the Administrator issuing the final order on October 9, 2025.
The process followed DEA regulations: issuance of the Order to Show Cause, opportunity for hearing, default due to non-response, and a Request for Final Agency Action. This streamlined approach is common when registrants do not contest allegations, as permitted under 21 CFR 1301.43 and 1316.67. No additional details on the reasons for the state suspension were provided in the Federal Register entry, focusing solely on the loss of state authority.
Implications and Perspectives
The revocation could disrupt Rezaei's ability to prescribe controlled substances, impacting his medical practice and patients reliant on such treatments. Short-term effects might include the need for patients to seek alternative providers, potentially straining local healthcare resources in Lawton. Long-term, it raises questions about reinstatement if Rezaei regains state authority, though federal policy typically requires a new application.
From a regulatory perspective, this action reinforces strict federal-state alignment in combating misuse of controlled substances, amid national concerns over opioid prescribing. Critics of such policies argue they may overly penalize practitioners for state-level issues without federal review of underlying causes, potentially deterring medical professionals. Supporters emphasize the necessity for accountability to prevent diversion. Legal experts note that while the DEA's approach is well-established, it invites debate on balancing enforcement with access to care.
The decision also highlights procedural efficiencies in default cases, which expedite resolutions but assume admissions without contest. This could prompt discussions on whether more outreach is needed to ensure registrants understand hearing rights.
In summary, the DEA's revocation of Rezaei's registration exemplifies the mandatory link between state and federal licensing for controlled substances. Potential next steps include Rezaei seeking reinstatement of his Oklahoma registration, which could pave the way for a new DEA application. Ongoing debates may focus on refining these interconnected regulatory frameworks to address enforcement challenges while supporting legitimate medical needs. Future cases could test the boundaries of exceptions or procedural fairness in similar defaults.