Dain v. Pawlewski

253 N.W.2d 582, 1977 Iowa Sup. LEXIS 1062
CourtSupreme Court of Iowa
DecidedMay 25, 1977
DocketNo. 2-58606
StatusPublished

This text of 253 N.W.2d 582 (Dain v. Pawlewski) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dain v. Pawlewski, 253 N.W.2d 582, 1977 Iowa Sup. LEXIS 1062 (iowa 1977).

Opinion

UHLENHOPP, Justice.

This appeal primarily involves interpretation of our rather complicated statute governing licensure of individuals to practice chiropractic. See Code 1973, ch. 151; 65 G.A. ch. 1144.

Two schools of thought appear to exist in Iowa as to the scope of chiropractic, represented respectively by the Chiropractic Society of Iowa and the Iowa Chiropractic Society. The former society holds the traditional view that chiropractic is limited to the location and correction, by spinal or other incidental adjustments by hand, of subluxated vertebrae which may be impinging upon the normal transmission of nerves and affecting the normal functions of tissues. The latter society would add the use of certain “other modalities” — heat, cold, exercise, and supports — not as independent therapy but as procedures incidental to the adjustments. As the Iowa law stood at the beginning of 1974, the practice of chiropractic was limited to the more restricted view espoused by the former society, Chiropractic Society of Iowa. Code 1973, § 151.1(2). The other modalities constituted part of physical therapy, licensed under chapter 148A of the Code.

More and more Iowa practitioners of chiropractic, however, began to use the other modalities incidental to the adjustments. A survey answered by 50% to 60% of the practitioners disclosed that 90% of them did so. Practitioners using the other modalities feared prosecution for infringing upon physical therapy.

In 1974 the legislature passed an act allowing chiropractic practitioners to use the other modalities under certain circumstances. 65 G.A. ch. 1144. In the previous Code of 1973, § 151.1(2) read:

For the purposes of this title the following classes of persons shall be deemed to be engaged in the practice of chiropractic: .
Persons who treat human ailments by the adjustment by hand of the articulations of the spine or by other incidental adjustment.

With the passage of the amendment, § 151.-1(2) reads:

For the purposes of this title the following classes of persons shall be deemed to be engaged in the practice of chiropractic: .
Persons who treat human ailments by the adjustment of the musculoskeletal structures, primarily spinal adjustments by hand, or by other procedures incidental to said adjustments limited to heat, [584]*584cold, exercise and supports, the principles of which chiropractors are subject to examination under the provision of section 151.3, but not as independent therapeutic means. (Italics added.)

This litigation mainly has to do with the portion we have italicized.

The amendatory act, chapter 1144, also contained the following new section which is involved in this litigation (now § 151.8 of the 1977 Code):

A chiropractor shall not use in his practice the procedures otherwise authorized by law unless he has received training in their use by a college of chiropractic offering courses of instructions approved by the board of chiropractic examiners.
Any chiropractor licensed as of July 1, 1974, may use the procedures authorized by law if he files with the board of chiropractic examiners an affidavit that he has completed the necessary training and is fully qualified in these procedures and possesses that degree of proficiency and will exercise that care which is common to physicians in this state.

We take it that “the procedures otherwise authorized1 by law” in this section refer to the incidental use of heat, cold, exercise, and supports specified in the newly-enacted definition of chiropractic.

Two other sections, which were not changed, are relevant to our inquiry:

§ 151.3. Every applicant for a license to practice chiropractic shall:
1. [Present evidence of education equal to graduation from secondary school.]
2. Present a diploma issued by a college of chiropractic approved by the chiropractic examiners.
3. Pass an examination prescribed by the chiropractic examiners in the subjects of anatomy, physiology, symptomatology and diagnosis, hygiene and sanitation, chemistry, histology, pathology, and principles and practice of chiropractic, including a clinical demonstration of vertebral palpation, nerve tracing and adjusting.

(To this list of subjects in § 151.3(3), we take it that the legislature has added incidental use of “heat, cold, exercise, and supports” by virtue of the clause in new § 151.-1(2), “the principles of which chiropractors are subject to examination under the provisions of section 151.3”.) Also:

§ 151.4. No college of chiropractic shall be approved by the chiropractic examiners as a college of recognized standing unless said college:
1. [Requires four academic years.]
2. Gives an adequate course of study . in the subjects enumerated in subsection 3 of section 151.3 and including practical clinical instruction.
3. [Publishes a catalogue.]

The amendments to chapter 151 took effect July 1, 1974. They did not pose a problem of application to students who still had a period of school after July 1, 1974; those students could take a course in the other modalities and thus comply with § 151.4(2) (which requires an adequate course in the subjects enumerated in § 151.-3(3) — now including the other modalities by virtue of the amendments). But application of the amendments posed problems for the board with respect to (a) those then-graduating students who would take the next license examination in August 1974 but who had not taken a course in the other modalities, and (b) individuals then licensed who had not taken such a course but desired to use the other modalities in their practice.

The board sought a way to apply the amendments to classes (a) and (b) in accordance with legislative intent. The testimony of the examiners and the minutes of their meetings are understandably somewhat unclear. Most chiropractic colleges already had a course of 120 hours in the other modalities. Palmer College of Chiropractic did not have a course but agreed to and did set up a course of 60 hours (increased to 120 hours by the fall of 1975, as we understand the record). All of these schools were approved colleges of the board so that, according to the testimony, if an individual took the course in one of these colleges he would in the judgment of the board have taken an [585]*585adequate course under § 151.4(2), if a student, or have completed the necessary training under new § 151.8, if a present practitioner. Moreover, since the course work was 120 hours, or 60 hours for the time being at Palmer, his course would automatically be 120 hours or 60 hours as the case might be. The board’s minutes were couched in terms of these number of hours, but the testimony of the chairman of the board demonstrates that the board’s decision actually was in terms of the courses given by approved colleges.

Specifically, the board decided to let students in class (a) take the examination in August 1974 except as to the other modalities. These students could then take Palmer’s 60-hour course, and the board would give them a special examination on the other modalities in the fall of 1974.

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Bluebook (online)
253 N.W.2d 582, 1977 Iowa Sup. LEXIS 1062, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dain-v-pawlewski-iowa-1977.