128

LAWS OF MARYLAND

Ch.8

chiropractic ... or to prohibit chiropractors from
practicing physical therapy in their practice as
chiropractors...". This same legislation also contained a
section that stated that physical therapists licensed under
the physical therapy subtitle, and no other, shall be known
as physical therapists and entitled to use related
designations.

The Court of Special Appeals has held that a
chiropractor who holds a license to practice chiropractic
with the right to practice physical therapy is competent to
testify in the area of physical therapy. Elliott v.
Patterson, 12 Md. App. 341 (1971). Footnote No. 2 at page
345 of the same case noted:

"Long prior to the creation of the Board of
Physical Therapy Examiners, chiropractics engaged
in the practice of physical therapy. The obvious
purpose of Section 614 was to assure the
chiropractic profession that it would not be
subject to licensure control by any Board other
than its own."

In this regard, see also Thomas v. Owens, 28 Md. App.
442 (1975).

Ch. 704, Acts of 1949 required that in order to obtain
a license to practice chiropractic "with the right to
practice physical therapy", chiropractors must be examined
on the subject of physical therapy as that term was defined
in the physical therapy subtitle. Therefore, after 1949,
two types of practice of chiropractic were permitted — both
of which involve doing acts that constitute "physical
therapy".

Although it is not clear exactly which acts of physical
therapy are included in the practice of chiropractic and
which additional acts are included in the definition of
"practice physical therapy" in § 13-101 of this article,- the
latter definition includes many methods of treatment beyond
the manual manipulation techniques that traditionally have
been the focus of the practice of chiropractic.

The Commission to Revise the Annotated Code of Maryland
has attempted to preserve accurately the meaning of the
present law. The General Assembly may wish to consider
whether clarification of the two types of practice of
chiropractic is necessary.

Miscellaneous.

Most of the present law that relates to chiropractors
was enacted by Ch. 666, Acts of 1920, and substantial style
changes were necessary in the revision.

There are two instances in which archaic references to
"schools" of chiropractic are made: present Art. 43, § 511