151 N.E. 197 (N.Y. 1926).

One-Sentence Takeaway:  Defendant chiropractor’s failure to secure a license as required by state statute could not be made the basis of negligence in a malpractice suit, since the violation had no direct bearing on the injury and the injury would not have been obviated had he been licensed.

Summary:  Defendant provided chiropractic treatments to Plaintiff which constituted the practice of medicine without a license in violation of state criminal law.  Those treatment left Plaintiff paralyzed.

The court concluded that the statutory violation was not causally related to Plaintiff’s injures because it was Defendant’s lack of skill, not the lack of license, that caused the injury and the injury would have occurred had Defendant possessed the license but nevertheless lacked or failed to exercised the requisite skill.

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