Collins v. Texas
1912 U.S. LEXIS 2234, 223 U.S. 288, 32 S. Ct. 286 (1912)
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Rule of Law:
A state, under its police powers, may constitutionally define the "practice of medicine" broadly to include non-traditional healing arts like osteopathy and require such practitioners to meet standardized licensing requirements, including graduation from a reputable school and examination on scientific subjects.
Facts:
- F.M. Collins practiced osteopathy for compensation in Texas, treating patients without administering drugs.
- Collins held a diploma from the American School of Osteopathy in Missouri, obtained after a two-year course of study.
- Before a new Texas law passed, Collins had invested $15,000 in his practice and was earning a significant income.
- In 1907, Texas enacted a statute defining the 'practice of medicine' to include anyone who treats or offers to treat any disease or disorder by any system or method for money.
- The statute required such practitioners to obtain a license from a Board of Medical Examiners, which necessitated passing an examination on scientific subjects including anatomy, physiology, chemistry, and pathology.
- After the law went into effect, Collins treated a patient for hay fever using osteopathy and charged a fee for the service.
- Collins never presented his diploma to the Board of Medical Examiners nor did he attempt to obtain a license as required by the 1907 statute.
Procedural Posture:
- Collins was charged by information in a Texas court with the offense of practicing medicine without a license.
- While being held on this charge, Collins filed a petition for a writ of habeas corpus, challenging the constitutionality of the licensing statute.
- The Texas Court of Criminal Appeals, the state's highest court for criminal matters, denied the writ of habeas corpus, upholding the statute.
- Collins then sought a writ of error from the Supreme Court of the United States to review the judgment of the Texas court.
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Issue:
Does a state law that defines 'practicing medicine' to include treating diseases by any system or method for compensation, and requires practitioners like osteopaths to obtain a license by demonstrating proficiency in various scientific subjects, violate the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Holmes
No, the Texas law does not violate the Fourteenth Amendment. A state may constitutionally prescribe conditions for the practice of the healing arts to ensure the competence of its practitioners. The court reasoned that since osteopathy professes to be a scientific method of healing, it is intelligible and rational for the state to require an osteopath to demonstrate a scientific training, including knowledge of subjects like anatomy and physiology. The court also noted that Collins could not claim the law was unconstitutional as applied to him because he never attempted to comply with it by seeking a license; therefore, he could not know if his osteopathic school would have been rejected. The fact that Collins had an established business before the law's passage does not grant him an exemption from new regulations designed to protect public health and safety, as established in precedents like Dent v. West Virginia.
Analysis:
This decision solidifies the broad scope of a state's police power to regulate professions related to public health. It affirmed that states can define 'medicine' beyond the traditional administration of drugs, thereby bringing alternative and emerging healing practices under the umbrella of state licensing boards. The ruling establishes that as long as licensing requirements are rationally related to ensuring practitioner competence, they will be upheld, even if they impact existing businesses. This precedent gives states considerable leeway in setting educational and testing standards for a wide array of health-related professions.
