NC General Statutes

N.C. Gen. Stat. § 90-157.2 (2026)

Chiropractor as expert witness

✓ current as of July 2026
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A Doctor of Chiropractic, for all legal purposes, shall be considered an expert in his field and, when properly qualified, may testify in a court of law as to:

(1) The etiology, diagnosis, prognosis, and disability, including anatomical, neurological, physiological, and pathological considerations within the scope of chiropractic, as defined in G.S. 90-151; and

(2) The physiological dynamics of contiguous spinal structures which can cause neurological disturbances, the chiropractic procedure preparatory to, and complementary to the correction thereof, by an adjustment of the articulations of the vertebral column and other articulations. (1977, c. 1109, s. 3; 1989, c. 555, s. 1.)

 

§ 90-157.3.  Ownership of chiropractic practices limited.

(a) Each partner in a partnership that is engaged in the practice of chiropractic shall be licensed under this Article.

(b) Each general partner in a limited partnership that is engaged in the practice of chiropractic and each limited partner who takes part in the control of the practice shall be licensed under this Article.

(c) The provisions of Chapter 55B of the General Statutes shall apply to all business corporations organized under Chapter 55 of the General Statutes and engaged in the practice of chiropractic. (1999-430, s. 2.)

 

Notes of Decisions
Cited in 10 cases, 1978–2015 · leading case: Blackmon v. Bumgardner, 519 S.E.2d 335 (N.C. Ct. App. 1999).
Blackmon v. Bumgardner, 519 S.E.2d 335 (N.C. Ct. App. 1999). · cites it 8× “Expert Witness Instruction Plaintiff contends the trial court erred in failing to instruct the jury that a chiropractor is an expert witness in accordance with N.C. Gen.Stat. § 90-157.2. That statute reads as follows: A Doctor of Chiropractic, for all legal purposes, shall be…”
Wooten v. Warren Ex Rel. Gilmer, 451 S.E.2d 342 (N.C. Ct. App. 1994). · cites it 8× “Brodar’s testimony were unresponsive and beyond the expertise of chiropractic as set forth in N.C. Gen. Stat. § 90-157.2 (1993). The bulk of defendant’s objections to Dr.”
Currence v. Hardin, 249 S.E.2d 387 (N.C. 1978). · cites it 3× “G.S. 90-157.2, enacted in 1977, says: “A Doctor of Chiropractic, for all legal purposes, shall be considered an expert in his field and, when properly qualified, may testify in a court of law as to etiology, diagnosis, prognosis, and disability, including anatomical,…”
Thomas v. Barnhill, 403 S.E.2d 102 (N.C. Ct. App. 1991). · cites it 7× “At the time Ellis was decided, G.S. 90-157.2 provided: A Doctor of Chiropractic, for all legal purposes, shall be considered an expert in his field and, when properly qualified, *553 may testify in a court of law as to etiology, diagnosis, prognosis, and disability, including…”
Winston v. Brodie, 517 S.E.2d 203 (N.C. Ct. App. 1999). · cites it 9× “Defendants maintain testimony concerning extremity injuries is beyond the scope of chiropractic as set forth in N.C.G.S. § 90-157.2 (1997). We do not agree.”
Head v. Adams Farm Living, Inc., 775 S.E.2d 904 (N.C. Ct. App. 2015). · cites it 2× “See N.C. Gen.Stat. § 90-157.2 (placing limits on medical issues as to which chiropractors can provide expert testimony in a court of law).”
Mitchem v. Sims, 285 S.E.2d 839 (N.C. Ct. App. 1982). “” Defendants object to the form of the question, arguing it is not stated in terms of reasonable chiropractic certainty. They also argue that no evidence of disability had been presented which could serve as a foundation for the question.”
Peaches v. Payne, 533 S.E.2d 851 (N.C. Ct. App. 2000). · cites it 2× “However, during redirect examination of plaintiffs’ chiropractor, on request of contem-nor, the court took judicial notice of N.C. Gen. Stat. § 90-157.2 (1999) (“Chiropractor as expert witness”), which sets forth matters to which a properly qualified chiropractor may testify.”
Currence v. Hardin, 243 S.E.2d 172 (N.C. Ct. App. 1978). · cites it 2× “The scope of testimony limited by the Allen case was recently expanded by G.S. 90-157.2. However, this statute is not applicable to the present case since it was not ratified until 1 July 1977.”
Ellis v. Rouse, 357 S.E.2d 699 (N.C. Ct. App. 1987). “G.S. 90-157.2 states: A Doctor of Chiropractic, for all legal purposes, shall be considered an expert in his field and, when properly qualified, may testify in a court of law as to etiology, diagnosis, prognosis, and disability, including anatomical, neurological, physiological,…”
— N.C. Gen. Stat. § 90-157.2(1) — 1 case
Thomas v. Barnhill, 403 S.E.2d 102 (N.C. Ct. App. 1991). “At the time Ellis was decided, G.S. 90-157.2 provided: A Doctor of Chiropractic, for all legal purposes, shall be considered an expert in his field and, when properly qualified, *553 may testify in a court of law as to etiology, diagnosis, prognosis, and disability, including…”
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