corporate practice of medicine doctrine (Illinois) · Go Syfert
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corporate practice of medicine doctrine in Illinois

13 Illinois opinions name it 2 courts 1997–2005 0 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
People v. United Medical Service, Inc.green
ill · 1936 · cited in 5 Illinois opinions naming this issue, 1997–2000
2 sentences

1998Relying on the Illinois Supreme Court’s decision in People v. United Medical Service, Inc., 362 Ill. 442 (1936), we explained that a corporation, even a hospital, was not allowed to employ physicians because such action constituted “practicing medicine” in violation of the corporate-practice-of-medicine doctrine.

1997Kerner v. United Medical Service, Inc., 362 Ill. 442 (1936), adopted the corporate practice of medicine doctrine, which prohibits corporations from employing physicians.

45
Carter-Shields, MD v. Alton Health Inst.green
ill · 2002 · cited in 4 Illinois opinions naming this issue, 2004–2005
2 sentences

2005As a final matter, we briefly dispense with Blue Cross’ argument that the appellate court’s holding below that the Act’s certificate of registration requirement is for the protection of the public is consistent with “Illinois’ well established policy of ensuring that lay people are not controlling or influencing professional services.” Citing to our decision in Carter-Shields v. Alton Health Institute , 201 Ill. 2d 441, 445 (2002), Blue Cross observes that the corporate practice of medicine doctrine prevents persons or entities that are not licensed by this state from providing physician or ot

2005As a final matter, we briefly dispense with Blue Cross’ argument that the appellate court’s holding below that the Act’s certificate of registration requirement is for the protection of the public is consistent with “Illinois’ well established policy of ensuring that lay people are not controlling or influencing professional services.” Citing to our decision in Carter-Shields v. Alton Health Institute, 201 Ill. 2d 441, 445 (2002), Blue Cross observes that the corporate practice of medicine doctrine prevents persons or entities that are not licensed by this state from providing physician or oth

34
Berlin v. Sarah Bush Lincoln Health Centergreen
ill · 1997 · cited in 5 Illinois opinions naming this issue, 1998–2002
2 sentences

2002Therefore, we concluded that because “a duly-licensed hospital possesses legislative authority to practice medicine by means of its staff of licensed physicians,” it is therefore “excepted from the operation of the corporate practice of medicine doctrine.” Berlin , 179 Ill. 2d at 19 .

2002Therefore, we concluded that because “a duly-licensed hospital possesses legislative authority to practice medicine by means of its staff of licensed physicians,” it is therefore “excepted from the operation of the corporate practice of medicine doctrine.” Berlin, 179 Ill. 2d at 19 .

25
Rush v. City of St. Petersburggreen
fladistctapp · 1967 · cited in 1 Illinois opinions naming this issue, 1997–1997
1 sentence

1997Petersburg, 205 So. 2d 11, 14 (Fla. App. 1967) (where the Florida appellate court found that the corporate-practice-of-medicine doctrine did not apply to hospitals).

11
Group Health Ass'n v. Moorgreen
dcd · 1938 · cited in 1 Illinois opinions naming this issue, 1997–1997
1 sentence

1997See Group Health Ass’n v. Moor, 24 F. Supp. 445 (D.C. 1938), aff’d sub nom.

11
Women's Medical Center v. Finleygreen
njsuperctappdiv · 1983 · cited in 1 Illinois opinions naming this issue, 1997–1997
1 sentence

1997See Women’s Medical Center v. Finley, 192 N.J.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Carter-Shields v. Alton Health Institute green
illappct · 2000
2 sentences

2002The appellate court reversed, holding that under the corporate practice of medicine doctrine and this court’s ruling in Berlin, the employment agreement between plaintiff and AHI was void and unenforceable. 317 Ill.

2002In the portion of the opinion designated as part “I,” the appellate court construed our decision in Berlin as reaffirming the viability of the corporate practice of medicine doctrine, and as creating a “narrow” exception to the application of the doctrine which arises only when “a licensed hospital *** enter[s] into contracts with physicians.” (Emphasis in original.) 317 Ill.

32002–2002
Darling v. Charleston Community Memorial Hospital green
ill · 1965
1 sentence

1997First, the hospital relies on the supreme court’s decision in Darling v. Charleston Community Memorial Hospital, 33 Ill. 2d 326 (1965), which held that a hospital could be directly liable for negligent medical treatment.

11997–1997
Dr. Allison, Dentist, Inc. v. Allison green
ill · 1935
2 sentences

1997The Illinois Supreme Court first addressed the corporate-practice-of-medicine doctrine in Dr. Allison, Dentist, Inc. v. Allison, 360 Ill. 638 (1935).

1997The Illinois Supreme Court first addressed the corporate-practice-of-medicine doctrine in Dr. Allison, Dentist, Inc. v. Allison, 360 Ill. 638 (1935).

11997–1997
St. Francis Regional Medical Center, Inc. v. Weiss green
kan · 1994
2 sentences

1997Then, the Weiss court stated that a contract was purely of a fiscal nature and to conclude that a hospital must accomplish what it is licensed to do "without employing physicians is not only illogical but ignores reality.” Weiss, 254 Kan. at 745 , 869 P.2d at 618 .

1997Then, the Weiss court stated that a contract was purely of a fiscal nature and to conclude that a hospital must accomplish what it is licensed to do "without employing physicians is not only illogical but ignores reality.” Weiss, 254 Kan. at 745 , 869 P.2d at 618 .

11997–1997

Statutes the citing opinions construe

IL § 225 ILCS 60/1 (9) IL § 210 ILCS 85/1 (6) IL § 225 ILCS 60/3 (5) IL § 805 ILCS 10/1 (5) IL § 805 ILCS 15/1 (5) IL § 805 ILCS 10/12 (4) IL § 805 ILCS 10/12.1 (4) IL § 805 ILCS 10/13 (4) IL § 805 ILCS 10/2 (4) IL § 805 ILCS 10/3.4 (4) IL § 805 ILCS 10/8 (4) IL § 805 ILCS 105/101.01 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 13 (1997–2005) WA 6 (2010–2021) CO 6 (2000–2026) CA 3 (1996–2002) MN 3 (2004–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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