Some Notes on England v. Louisiana State Board of Medical Examiners

Stephen Barrett, M.D.
August 8, 2018

In 1965, in what was then a landmark opinions, a federal district court ruled that a state could properly refuse to license chiropractors unless they meet the same educational standards required of medcal doctors. In 1966 , the U. S. Supreme Court held upheld this ruling and later denied the chiropractor’s petition for a rehearing.

The district court decision—in which all three three judges concurred—had rejected the chiroprctors’ argument that their constitutional rights had been violatcd, The judges found that “there has been no showing here that the state had done more than is necessary to protect the hcalth of its citizens.” They also said:

If the education obtaiined in chiropractic school doss not meet the standards of . . . the United States Office of Education, it may well be that the Legislature ot Louisiana felt that in the public interest a diploma from an approved medical school should be required of a chiropractor before he is allowed to treat all the human ailments chiro practors contend can be cured by manipulation of the spine.

Citing information from chiropractic textbooks, the court ruling also noted:

As broadly defined by its proponents, chiropractic is a healing art designed to relieve human ailments by manipulation and adjustment of the spine. It is chiropractic doctrine that most, if not all, human ailments result from a slight misalignment, or subluxation, of contiguous vertebrae. This subluxation tends to impinge on nerves emanating from the spinal cord through apertures in the vertebrae. As a result of the impingement, the innervation to the parts of the body served by the impinged nerve is abnormally altered, and such parts become diseased or predisposed to disease The realignment of these subluxated vertebrae through manipulation of the spine by the chiropractor removes the impingement and restores the nerve function to the diseased part.s of the body. Chiropractic science postulates that the commonly accepted cause of disease, such as viruses and germs, are merely secondary factors acting on parts of the body already predisposed to disease by nerve impingement Thus disease results from a lack of resistance to the viruses and germs which are always present in the body.

There seem to be two schools of chiropractic. The members of the International ‘Chiropractors Association apparently believe that there is one cause of disease—subluxation of the vertebrae and one cure—manipulation of the spine to relieve the subluxation. The Amencan Chiropractic Association, while not as absolute in its approach to the problem of disease, nevertheless feels that chiropractic is a complete and independent healing art which not only can prevent disease, but can cure disease if the manipulation of the spine begins in time.

In 1968, the AMA Law Division commented:

The England case is significant because it substantiates medicine’s position that chiropractic is an unscientific cult. The court ruled after a detailed review of chiropractic principles and practices as presented by chiropractic’s leading spokesmen. The public generally has little awareness of the shortcomings of chiropractic theory and education. The England case serves to increase public awareness. The decision, with its affirmance by the U.S. Supreme Court, represents a clear precedent for the federal courts, and a persuasive authority for all state courts. The opinion of the courts was that it is not irrational and unreasonable for a state legislature, as a means of protecting the health of its citizens, to require chiropractors to meet the same requirements as doctors of medicine. In effect, the nation’s highest courts thus held for one scientific standard of health care [2].

During the trial, affidavits were submitted from nine specialists in different fields who explained how chiropractic was based on false concepts and was dangerous [3].


  1. Opinion. Jerry R. England et al. v. Lousiana Board of Medical Examiners et al. U.S. District Court for the Eastern District of Lousiana, New Oeleans Division, Civil action No. 9292-A, Nov 9, 1965.
  2. AMA Law Division. No double standards for patient care. JAMA 206:21910-2192, 1968.
  3. Affidavits submitted in the England case.

This article was posted on August 8, 2018.