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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 03-14-00396-CV
Regular Panel Decision
Jan 06, 2015

Texas Board of Chiropractic Examiners and Yvette Yarbrough, Executive Director v. Texas Medical Association

The Texas Board of Chiropractic Examiners (TBCE) and its Executive Director, Yvette Yarbrough, are appealing a decision from the Third Court of Appeals in Austin, Texas. They have filed a motion for panel rehearing and/or en banc rehearing. The appellants argue that the Court's previous memorandum opinion contains three fundamental errors: misstating appellate issues, resolving subject-matter jurisdiction using a prohibited method, and misstating the administrative rule at issue. They contend that the Court misunderstood their challenge to the trial court's jurisdiction regarding the Texas Medical Association's (TMA) claim to invalidate a provision of the Scope of Practice Rule (22 Tex. Admin. Code § 75.17(d)(1)) concerning chiropractors' authority to "diagnose" diseases. TBCE asserts that this claim is a collateral attack on a prior judgment in TMA I where the same issue was litigated and decided in TBCE's favor. They argue that subject-matter jurisdiction should be decided on a claim-by-claim basis and that the Court erred in its interpretation of the administrative rule number. They are requesting an opportunity for oral argument due to the significance of the issues for chiropractic practice in Texas.

Workers' CompensationChiropractic Scope of PracticeMedical AssociationCollateral AttackSubject Matter JurisdictionAdministrative LawRule InvalidationTexas LawAppellate ProcedureMotion for Rehearing
References
6
Case No. 03-10-00673-CV
Regular Panel Decision
Jul 06, 2012

Texas Board of Chiropractic Examiners, Glenn Parker, Executive Director, and Texas Chiropractic Association v. Texas Medical Association, Texas Medical Board, and the State of Texas

This case concerns an appeal by the Texas Board of Chiropractic Examiners (TBCE) and the Texas Chiropractic Association (TCA) challenging a district court's judgment. The district court invalidated portions of TBCE's administrative rule defining the scope of chiropractic practice, specifically regarding manipulation under anesthesia (MUA), needle electromyography (needle EMG), and certain diagnostic activities. The Court of Appeals affirmed the invalidation of rules permitting needle EMG and MUA, finding them to be "incisive" and "surgical" procedures respectively, and thus exceeding the statutory scope of chiropractic. However, the appellate court reversed the invalidation of rules allowing chiropractors to make certain diagnoses concerning the biomechanical condition of the spine or musculoskeletal system and subluxation complex, concluding these were within the statutory scope. The case was remanded for further proceedings regarding alternative constitutional challenges.

Chiropractic regulationMedical scope of practiceAdministrative rulesStatutory interpretationNeedle EMGManipulation Under AnesthesiaChiropractic diagnosisTexas lawHealth professional licensingJudicial review
References
98
Case No. 18-1223
Regular Panel Decision
Jan 29, 2021

Texas Board of Chiropractic Examiners Patrick Fortner, in His Official Capacity as the Board's Executive Director And Texas Chiropractic Association v. Texas Medical Association

This decade-long case addresses the legal boundary between chiropractic and medical practices in Texas. The Texas Board of Chiropractic Examiners (the Board) issued rules defining the musculoskeletal system and subluxation complex to include nerves, and also authorized chiropractors to perform Vestibular-Ocular-Nystagmus Testing (VONT). The Texas Medical Association (TMA) challenged these rules, arguing they allowed chiropractors to engage in the unlicensed practice of medicine. The Supreme Court of Texas reversed the court of appeals' judgment, holding that the Board's rules are valid. The Court concluded that the rules, read in context with other referral requirements, appropriately clarify the scope of chiropractic practice without infringing upon medical neurology, and that VONT can be used by chiropractors for diagnostic purposes within their defined scope.

Chiropractic PracticeMedical RegulationScope of PracticeAdministrative LawAgency RulemakingTexas Supreme CourtMusculoskeletal SystemSubluxation ComplexVONT TestingStatutory Interpretation
References
31
Case No. ADJ11446545
Regular
Dec 03, 2019

ROSA LOPEZ RODRIGUEZ vs. UNIVERSAL BUILDING SERVICES SUPPLY COMPANY, INSURANCE COMPANY OF THE WEST

This case concerns a dispute over the appropriate medical specialty for a Qualified Medical Evaluator (QME) panel. The applicant, Rosa Lopez Rodriguez, initially requested a chiropractic QME panel, which was issued first. The defendant objected, arguing that chiropractic was inappropriate due to the applicant's prior surgery and lack of full recovery. The Medical Unit then invalidated the chiropractic panel and issued an orthopedic surgery panel. The Workers' Compensation Appeals Board granted reconsideration, overturning the WCJ's decision. The Board held that the party who first requests a QME panel has the right to designate the specialty and that the defendant failed to provide sufficient grounds to invalidate the chiropractic panel. Therefore, the Board amended the findings to sustain the applicant's objection and affirm chiropractic as the appropriate panel specialty.

AD Rule 31.5(a)(10)AD Rule 31.5(a)(9)AD Rule 31.1(b)Labor Code section 4062Labor Code section 4062.2Qualified Medical Evaluator (QME)QME panel specialtyPetition for RemovalPetition for ReconsiderationMedical Unit determination
References
1
Case No. ADJ9796670
Regular
Aug 05, 2016

Virginia Lopez vs. California Pizza Kitchen, Travelers Insurance

Applicant Virginia Lopez sought removal after an administrative law judge (WCJ) invalidated a chiropractic QME panel, ordering an orthopedic replacement. The Workers' Compensation Appeals Board (WCAB) granted removal, finding the original chiropractic panel was properly issued and defendants waived their right to object by failing to follow proper procedures. The WCAB amended the WCJ's decision to affirm the chiropractic panel, deeming removal necessary to prevent substantial prejudice. The WCAB affirmed the WCJ's order to issue a replacement panel in the "specialty previously issued," which was chiropractic.

Petition for RemovalQualified Medical Evaluator (QME)Specialty DesignationCompensability ExamLabor Code § 4060Rule 30(b)Rule 31.1(b)Written ObjectionMedical Director ReviewWaiver of Objection
References
6
Case No. ADJ12910087
Regular
Dec 28, 2020

ESTHER LEMUS SALDANA vs. TAO TAI HOMES CORPORATION, INSURANCE COMPANY OF THE WEST

This case concerns a dispute over the correct Qualified Medical Evaluator (QME) panel for applicant Esther Lemus Saldana. The defendant sought reconsideration of an order finding the applicant's chiropractic QME panel valid and the defendant's orthopedic panel invalid. The Workers' Compensation Appeals Board denied the petition, upholding the administrative law judge's decision. The Board found the applicant properly requested a new panel after retaining counsel, and despite a service error on the chiropractic panel, the defendant had opportunity to contest the specialty. Therefore, the applicant's chiropractic QME panel remains the correct one for the medical-legal evaluation.

QME PanelChiropractic QMEOrthopedic QMEPetition for ReconsiderationFindings of Fact and OrdersMedical-Legal EvaluationQualified Medical EvaluatorAdministrative Director RuleRomero v. Costco WholesaleLabor Code Section 4062.1
References
9
Case No. 3-15-00262-CV
Regular Panel Decision
Aug 10, 2015

Texas Association of Acupuncture and Oriental Medicine v. Texas Board of Chiropractic Examiners And Patricia Gilbert, Executive Director in Her Official Capacity

This is an Administrative Procedures Act challenge to the validity of Chiropractic Board rules that authorize chiropractors to engage in the unlicensed practice of acupuncture. The Association sought to invalidate these rules and alternatively sought a declaration that the statutory scheme allowing chiropractors to practice acupuncture is unconstitutional. The trial court granted the Chiropractic Board’s motion for summary judgment and denied the Association’s competing motion. The Association argues that the Chiropractic Board exceeded its statutory authority, and its interpretation of the Acupuncture Chapter is unreasonable and creates public health risks due to inadequate training. Alternatively, the statutory scheme violates the Texas Constitution by favoring one school of medicine and containing more than one subject. The Association also argues that the statute of limitations defense fails.

Administrative LawScope of PracticeChiropractic RegulationAcupuncture RegulationStatutory InterpretationConstitutional LawSeparation of PowersDelegation of AuthorityPublic Health and SafetyProfessional Licensing
References
97
Case No. ADJ11426145
Regular
Aug 16, 2019

MARIA RESENDIZ vs. TAMBRO, INC., INSURANCE CO. OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration, reversing a WCJ's finding and ruling that a chiropractic QME panel, not an orthopedic one, is appropriate for this claim. The Board found the Medical Director's basis for invalidating the chiropractic panel was insufficient, as QMEs cannot provide treatment or opine on disputed treatment issues. The case now requires the parties to utilize the chiropractic QME panel for evaluation. This decision aligns with persuasive reasoning from a prior panel decision regarding specialty disputes.

QME panelchiropractic specialtyorthopedic surgeryspecialty disputeMedical Directorutilization reviewpermanent and stationary statusscope of practicescope of evaluationAD Rule 31.1(b)
References
1
Case No. ADJ11861160
Regular
Oct 25, 2019

ADRIANA MARTINEZ vs. AVITUS, AMERICAN ZURICH INSURANCE COMPANY, GALLAGHER BASSETT SERVICES

This case involves a dispute over the selection of Qualified Medical Evaluator (QME) panels for an applicant with claimed injuries to multiple body parts. The Workers' Compensation Appeals Board (WCAB) granted the applicant's petition for removal, rescinded the prior decision, and found that the applicant's chiropractic QME panel request was proper while the defendant's orthopedic surgery panel request was improper. The WCAB determined that chiropractic medicine is the appropriate specialty and struck the orthopedic surgery panel, ordering the parties to proceed with the chiropractic QME. The WCAB clarified that while chiropractors cannot perform surgery or prescribe medication, they are qualified to evaluate injuries within their scope of practice.

QME panel disputeremoval petitionchiropractic specialtyorthopedic surgery specialtyLabor Code 4062.2Medical Directoradministrative law judgeWorkers' Compensation Appeals Boardproper panel selectioninvalid panel request
References
9
Case No. 03-00-00513-CV
Regular Panel Decision
Apr 12, 2001

Continental Casualty Company v. the Texas Board of Chiropractic Examiners

Continental Casualty Company (insurer) sued the Texas Board of Chiropractic Examiners (Board) seeking a declaratory judgment regarding the validity of the Board's opinion that manipulation under anesthesia and needle electromyography are within the scope of chiropractic practice. Continental, a workers' compensation insurer, argued it would be forced to pay chiropractors for services they cannot legally perform. The Board filed a plea to the jurisdiction, which the trial court granted, dismissing the suit for want of jurisdiction. On appeal, the Third District Court of Appeals affirmed the trial court's judgment, concluding that assuming jurisdiction would result in an impermissible advisory opinion as there was no justiciable controversy between Continental and the Board, and Continental's complaint was arguably against the Workers' Compensation Commission.

Declaratory JudgmentWorkers' CompensationChiropractic PracticeScope of PracticeAdvisory OpinionJurisdictionSovereign ImmunityAdministrative Procedure ActJusticiable ControversyTexas Law
References
16
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