Pulley v. Maine State Board of Chiropractic Licensure

CourtSuperior Court of Maine
DecidedJuly 12, 2005
DocketKENap-04-66
StatusUnpublished

This text of Pulley v. Maine State Board of Chiropractic Licensure (Pulley v. Maine State Board of Chiropractic Licensure) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pulley v. Maine State Board of Chiropractic Licensure, (Me. Super. Ct. 2005).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION

KENNEBEG, ss. DOCKET NO. AP-04-66 MATTHEW W. PULLEY, D.C.,

Petitioner

v. DECISION AND ORDER

MAINE STATE BOARD OF CHIROPRACTIC LICENSURE,

Respondent

This matter is before the court on petition for review pursuant to 5 M.RS.A. § 1102, 10 M.R.S.A. § 8003(5) and MLR. Civ. P. 80C.

Pursuant to complaints, the Maine State Board of Chiropractic Licensure (Board) held a hearing and deliberative session to determine whether to take disciplinary action against Matthew Pulley, D.C. (petitioner) on his license to practice as a chiropractor. The hearing encompassed two full days and well into a night resulting in 1,236 pages of typed transcript. The Board concluded that Dr. Pulley had violated Board statutes and rules, did not appear to understand what he did wrong or the harm caused by his actions or to show any remorse to the complainants. The Board ordered that petitioner’s license to practice be suspended for a four-month period in addition to the initial investigative suspension, that the petitioner receive a reprimand and that petitioner’s license be placed on probation for a period of five years with the conditions that he attend and complete an Ethics and Boundaries approved course, have a female state-certified chiropractic assistant present when he treats female patients, receive counseling to the satisfaction of the Board, attend and pass an activator methods course,

attend and pass an additional course in the Logan Basic Technique, attend and pass a

pre-approved recordkeeping course, allow random inspections by the Board’s staff and to pay costs of the hearing. When the petition was filed, Dr. Pulley represented to the Board that he had attended and passed the Ethics and Boundaries course, that he had received the appropriate counseling, that he had completed and passed a proficiency course in activator methods, that he had removed the Logan Basic Technique as part of his practice, that he had attended and passed a recordkeeping course and that he had paid the assessment. Accordingly, petitioner asks relief from this court from the requirement of the length of his probation at five years and that he be required to have present a state-certified chiropractic assistant when treating female patients.

Petitioner first argues that the five-year period of probation is excessively long and is neither authorized by the statute nor consistent with the evidence in the case. Most specifically, petitioner notes that the period of probation exceeds any period of suspension of a practitioner’s license the Board was authorized to impose under 10 M.R.S.A. § 8003(5)(A-1)(2), a limitation of 90 days for each violation. Dr. Pulley points out that even if the Board were to consider each instance of violation as a separate actionable event, it could encompass no more than 16 violations.

Secondly, petitioner argues that deliberating into the late hours of the evening, the Board arbitrarily selected five years without substantiation in the evidence. With regard to the “chaperone” issue, Dr. Pulley asserts that he has now gone to an “open adjustment” method of practice in which, according to his petition, “patients are adjusted while clothed and in an open area observable by other patients, staff, and professionals.” He argues, under those circumstances, that he does not need a chaperone present because, among other things, no clothing is removed. Furthermore, petitioner believes that requiring the chiropractic assistant to be state-certified is

arbitrary, capricious, without statutory authorization and without basis on the record.

At argument, petitioner pointed out that certified chiropractic assistants are few and far between and difficult to find to employ.

The Maine State Board of Chiropractic Licensure comes under 10 M.R.S.A. § 8003 under the Office of License and Registration within the Division of Administrative Services. Section 8003(5) provides the authority to the Board. It states:

In addition to authority otherwise conferred, unless expressly precluded by

language of denial in its own governing law, each . . . board within or affiliated with the department may take one or more of the following actions ...

(Emphasis supplied).

The statute goes on to provide that for each violation of the law or regulation or conditions of licensure, the Board may:

Suspend a license or registration for up to 90 days for each violation of

applicable laws, rules and conditions of licensure or registration or for

instance of actionable conduct or activity...

10 M.R.S.A. § 8003(5)(A-1)(2) (2004).

Impose conditions of probation upon an applicant, licensee or registrant. Probation may run for such time period as the... board determines appropriate.

10 M.R.S.A. § 8003(5)(A-1)(4) (2004) (emphasis supplied).

Disciplinary actions of the Board of Chiropractic Licensure are mandated by 32 M.R.S.A. § 503-A. The grounds of discipline appear in 32 M.RS.A. § 503-A(2) authorizing the Board to suspend or revoke a license pursuant to 5 M.R.S.A. § 10004 for,

among other things, the following activities:

E. Incompetence for which the licensee is licensed. A licensee is considered incompetent in the practice if the licensee has:

(1) | Engaged in conduct that evidences a lack of ability or fitness to discharge the duty owed by the licensee to a client or patient or the general public; or

(2) Engaged in conduct that evidences a lack of knowledge or inability to apply principles or skills to carry out the practice for which the licensee is licensed.

F. Unprofessional conduct. A licensee is considered to have engaged

in unprofessional conduct if the licensee violates a standard of

professional behavior that has been established in the practice for which

the licensee is licensed.

In its decision, the Board voted that the petitioner violated 32 M.R.S.A. § 503- A(2)(E) by demonstrating a lack of ability in his treatment of a patient. The Board found a violation of 32 M.R.S.A. § 503-A(2)(F) by failing to maintain the dignity or modesty of two patients. The Board found that Dr. Pulley had violated provisions of its rules by intentionally or recklessly causing physical or emotional harm to a patient. The Board found that the petitioner had violated a provision of its rule by falsifying patient record. The Board found that Dr. Pulley violated a Board rule by engaging in sexual impropriety with respect to female patients. The Board found that petitioner violated its rule in engaging in inappropriate sexual comments. The Board found that Dr. Pulley violated its rule by examining patient areas that may be misconstrued as sexual exploration without verbal or written consent. The Board found that petitioner violated its rule by failing to respect the right and dignity of each patient. The Board found that Dr. Pulley violated its rule by failure to examine members of his staff prior to treating them. Finally, the Board specifically found that petitioner had violated 32 M.R-S.A. § 503-A(2)(H), the general statutory provision providing a grounds for discipline by a person who has violated Chapter 9 of Title 32, The Chiropractic Licensing Law or a rule

adopted by the Board.’

1 It is to be noted that the Board found that the petitioner did not engage in conduct evidencing a lack of skills, did not violate a term of agreement with another chiropractic doctor, did not violate a rule by touching the genitals of a patient, and did not violate the rule by engaging in sexual activity with a patent.

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Pulley v. Maine State Board of Chiropractic Licensure, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pulley-v-maine-state-board-of-chiropractic-licensure-mesuperct-2005.