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The Appellate Court Limits Chiropractic Care in New Jersey


Chiropractors and their patients need to be aware of an important recent intermediate court decision which limits the scope of chiropractic practice in New Jersey. In Bedford v. Riello, 2007 WL 1135521 (N.J.Super.A.D.), decided on April 18, 2007, the Appellate Division held that that chiropractors in New Jersey are limited in their practice to adjustments of the spine itself. Manipulation or adjustments of peripheral joints, such as shoulders, elbows, knees and ankles, are not within the “scope” of chiropractic practice as defined by statute in New Jersey.

The Appellate Division reached this conclusion by examining both the relevant statute passed by The State Legislature and the corresponding regulation promulgated by The State Board of Chiropractic Examiners in 1991. The controlling statute, N.J.S.A. 45:9-14.5, defines the practice of chiropractic as: “A system of adjusting the articulations of the spinal column by manipulation thereof.” The related regulation, N.J.A.C. 13:44E-1.1 (a), however, includes additional language not in the statute. It reads instead: “The practice of chiropractic is that patient heath care discipline whose methodology is the adjustment and/or manipulation of the articulations of the spine and related structures.”

For many years, chiropractors have interpreted this additional language to mean that they were within the scope of their practice in adjusting these peripheral joints so long as they were careful to show that the problem of the joint “related back” to a problem in the spine itself. Take for example, the problem of a twisted knee. The rotation of the knee rotates the corresponding hip outward. This hip distortion then causes twisting of the lower spine and resultant pain in the back. Under the language of the regulation, the patient's chiropractor would have proceeded first by documenting the causal relationship of the knee to the spinal misalignment, and then correcting both.

However, the opinion of the Appellate Division is that The State Board of Chiropractic Examiners misinterpreted the intent of the Legislature when writing the regulation fifteen years ago. Since the statute does not mention “related structures,” the court decided that Board exceeded their authority by adding these words when composing the regulation. Therefore, the court has decided these peripheral joint manipulations, whether documented to be related to the spine or not, are outside the scope of chiropractic medicine as authorized by statute.

For the time being, the Association of New Jersey Chiropractors is advising their members to refrain from any peripheral joint manipulation until the situation is clarified. The chiropractors are appealing their case to The New Jersey Supreme Court.

This decision is also important because it creates an additional theory of liability against a chiropractor. If the treatment is outside what is permitted as part of their license if the chiropractor can be found negligent even if the treatment was done properly and harm occurred. Chiropractors should be aware of this ruling and patients should be aware of the limitations on what chiropractors are licensed to do in the State of New Jersey.

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