Isles Wellness, Inc. v. Progressive Northern Insurance Co.

Summary

The Minnesota Supreme Court considered whether lay ownership of clinics providing chiropractic, physical therapy, and massage therapy services violated Minnesota's corporate practice of medicine doctrine. The court held that the doctrine applies to chiropractic, but not to physical therapy or massage therapy, and remanded in part. The court also declined to abandon the doctrine, concluding that any policy change should be addressed by the legislature.

Holdings

1. Minnesota recognizes a corporate practice of medicine doctrine that generally prohibits corporations from practicing licensed health care professions, subject to statutory or regulatory exceptions.
2. The corporate employment of chiropractors is prohibited by Minnesota's corporate practice of medicine doctrine unless expressly permitted by statute or regulation.
3. The corporate employment of physical therapists is not prohibited by Minnesota's corporate practice of medicine doctrine.
4. The corporate employment of massage therapists is not prohibited by Minnesota's corporate practice of medicine doctrine.
5. The Supreme Court did not decide whether the insurers were required to pay outstanding amounts billed for services provided by the clinics.

Questions Presented

1. Whether Minnesota recognizes a corporate practice of medicine doctrine.
2. Whether the doctrine prohibits a general business corporation from employing chiropractors.
3. Whether the doctrine prohibits a general business corporation from employing physical therapists.
4. Whether the doctrine prohibits a general business corporation from employing massage therapists.
5. Whether the insurers were required to pay the clinics' outstanding bills for services provided.

Disposition

reversed_and_remanded