The NMAT and medical-school eligibility

Facts and context

Applicants to medical schools for academic year 1987–1988 had not taken or passed the National Medical Admission Test. They challenged the Medical Act provisions authorizing the Board of Medical Education to prescribe admission requirements and a 1985 education order making the NMAT a condition for a certificate of eligibility. After the trial court refused a preliminary injunction, they sought certiorari in the Supreme Court.

Issue

Could the government require the NMAT and a minimum score for medical-school admission under the Medical Act without violating constitutional protections or the limits on delegated rulemaking?

Ruling and doctrine

The Court dismissed the petition and affirmed the denial of an injunction. Sections 1, 5, and 7 of the Medical Act supplied standards for the Board’s rulemaking; the NMAT bore a reasonable relation to the public interest in competent medical care. The Court also accepted flexibility in setting different cutoff scores for different admission years. Section 7(b) matters because the certificate of eligibility is the statutory admission document to which the NMAT requirement was attached.

Practice implications

Parao Law practice guidance

For applicants and medical schools

• Check the current admission order, testing schedule, cutoff, and certificate requirements for the relevant application year; the 1985 order considered in this case is historical context.
• Make the admission criteria and their source clear before applications open. Keep a record of each applicant’s test result and the basis for an eligibility determination.
• Treat the statutory certificate and any separate school-specific criteria as distinct requirements when advising applicants.

For lawyers

• Trace an admission condition to the Medical Act’s objectives and the Board’s specific powers, then identify the regulation in force when the applicant sought admission.
• A challenge to a particular cutoff requires evidence that it is unfair or unreasonable in its actual operation; the Court did not treat year-to-year variation alone as unconstitutional.

Limits of the ruling

The judgment upheld the NMAT framework challenged in 1987. It does not validate every future cutoff or dispense with review of later admission rules and their implementation.