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In Rogers v. Composite State Board of Medical Examiners, the Georgia Supreme Court dismissed as moot a constitutional challenge to the subpoena power of the State Board of Medical Examiners. Dr. John Rogers, a physician in Columbus, Georgia, was involved in civil litigation with the board concerning its composition and the appointment of its members. The final disposition of this suit was in Rogers' favor. While this litigation was pending, Rogers was served with a subpoena to furnish certain information from his patient files to the Board's investigator. Rogers was informed that a criminal investigation was being conducted, however, the investigator refused to respond to Rogers' questions concerning the nature of the charges against him or the identity of his accusers. Rogers refused to comply with the subpoena.