Mandatory language in state licensing law did not actually require a board to order a mental evaluation of a licensee before it disciplined him for impairment, a Minnesota court held May 4. The court upheld board discipline imposed on a chiropractor who shared with his wife emails—including medical information—of a patient with whom he was romantically involved.
The licensee in the case, a chiropractor named Alan Woggon, began to cross the professional boundary line with one of his patients in early 2018, informing her via email that he was in love and asking to pursue a romantic relationship. The patient seems to have reciprocated to some extent, and, although the two never engaged in sexual intercourse, the evidence of the relationship, consisting of nude photos, hundreds of sexually explicit texts, and emails, established its sexual nature.
When the patient asked Woggon about the rules regarding romantic relation-ships between chiropractors and patients, Woggon told her that there was a two-year buffer period, and that he had destroyed all the records of their conversations on the matter and taken other actions to hide their relationship.
In June 2018, Woggon’s wife discovered the relationship. Outed, Woggon sent his wife copies of his correspondence with the patient, including emails containing the patient’s medical information, even one the patient had sent Woggon with a link to all of her other medical records. In July, Woggon ended the relationship with the patient and referred her to another chiropractor. In October, the patient filed a complaint with the board.
Following a hearing, the board found that Woggon had improperly engaged in a relationship of a sexual nature with the patient, that substance abuse had impaired his ability to practice, and that he had improperly exposed the patient’s