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Practice Management Associates, Inc. v. Wakefield
Citations: 615 So. 2d 846; 1993 Fla. App. LEXIS 3002; 1993 WL 77516Docket: No. 92-01341
Court: District Court of Appeal of Florida; March 16, 1993; Florida; State Appellate Court
In a conflict of laws case, Practice Management Associates, Inc. (PMA) appealed a final summary judgment favoring chiropractors, contending that the trial court erroneously determined that their contract mandated illegal fee splitting under Wisconsin law. The appellate court agreed with PMA, asserting that the contract does not necessitate illegal fee splitting, and reversed the trial court's judgment, referencing the precedent set in Practice Management Associates, Inc. v. Orman, which, although based on Illinois law, was deemed applicable due to the substantial similarity between Illinois and Wisconsin fee-splitting statutes. Specifically, Illinois law prohibits fee splitting with anyone other than partnered physicians, while Wisconsin law similarly restricts chiropractors from splitting fees except with licensed associates. Given the comparable nature of these statutes, the court concluded that the contract in question does not entail illegal fee splitting. Consequently, the final summary judgment in favor of the chiropractors was reversed, with judges Danahy and Patterson concurring.