Chiropractic scope of practice in South Dakota

The practice of chiropractic in South Dakota is legally defined as "the science of locating and removing the cause of any abnormal transmission of nerve energy including diagnostic and applied mechanical measures incident thereto" ¹. This scope is codified in state law, primarily within South Dakota Codified Law (SDCL) Chapter 36-5, and further articulated by the South Dakota Board of Chiropractic Examiners through the Administrative Rules of South Dakota (ARSD) ². The Board is the state's regulatory body responsible for licensing, setting standards, and enforcing the practice act, including taking disciplinary action for unprofessional conduct such as practicing outside the legal scope ³, ⁴. This legal framework defines the specific procedures and services that a licensed Doctor of Chiropractic may provide to patients within the state.

At the core of the South Dakota scope of practice is the treatment of the human body through manual procedures. The foundational statute authorizes the "treating of specific joints and articulations of the body and adjacent tissues...by manipulation, adjustment, and mobilization of a joint" ¹. The Board's administrative rules provide a specific definition for a "chiropractic adjustment" as a passively applied movement of low amplitude and high-velocity thrust which moves a joint into the paraphysiological range ⁵. In addition to these manual therapies, chiropractors are authorized to use physiotherapeutic measures such as heat, cold, exercise, and mechanical forces ⁶. While a specific list of modalities is not provided in statute, their use is acknowledged in the required coursework for chiropractic assistants, which includes instruction on physiotherapy and modalities as directed by a supervising chiropractor ⁷.

Diagnostic authority is a key component of the scope, encompassing physical examinations and the use of "Chiropractic radiography," defined by SDCL 36-5-1.1 as "the application of X-radiation within the scope of practice of chiropractic for diagnostic purposes only" ⁸, ⁹. Licensed chiropractors are authorized to perform these radiographic procedures without obtaining the separate, specific registration required for chiropractic radiographers ¹⁰. Beyond general practice, the scope in South Dakota allows for expansion into specialized areas with additional certification. A chiropractor may perform acupuncture after providing proof of passing the National Board of Chiropractic Examiners (NBCE) acupuncture examination ¹¹. Animal chiropractic is also permitted, but it is strictly regulated; a chiropractor must complete a board-approved course of at least 210 hours and may only treat an animal upon referral from a licensed veterinarian ¹², ¹³.

The legal framework also implicitly or explicitly prohibits certain activities. The state's practice act and administrative rules do not authorize chiropractors to perform dry needling ², ¹⁴. While the statutes do not explicitly detail the bounds of nutritional advice, the scope is generally understood to include therapeutics taught in approved chiropractic schools ¹⁵. In addition to clinical treatment, South Dakota law grants chiropractors specific authority in matters of public health and safety, including the ability to certify a patient's fitness for participation in athletics ¹⁶ and to withdraw a patient from work or athletic activities for a health-related reason ¹⁷.

Governing legal framework: statutes and board authority

The scope of chiropractic practice in South Dakota is delineated by a dual regulatory structure composed of state law and the administrative authority of a licensing board. The primary source of legal authority is the South Dakota Codified Law (SDCL), specifically Chapter 36-5, which provides the foundational definitions and boundaries for the profession ². This statute is complemented by the South Dakota Board of Chiropractic Examiners (SDBCE), the entity empowered by the legislature to create and enforce specific administrative rules that interpret and implement the legislative mandate. This model of state statute and an associated professional board is a common framework in the United States, reflecting the profession's historical efforts to gain legal recognition and establish standardized practice, a process documented in texts such as The secret history of chiropractic ¹⁸.¹⁹

The state statute, SDCL Chapter 36-5, establishes the fundamental legal definition of chiropractic. According to SDCL 36-5-1, the practice is defined as "the science of locating and removing the cause of any abnormal transmission of nerve energy including diagnostic and applied mechanical measures incident thereto" ¹. The law further specifies that this includes treating joints and adjacent tissues through "manipulation, adjustment, and mobilization" ¹. The statute also grants chiropractors specific authority in related diagnostic and public health functions. For example, SDCL 36-5-1.1 explicitly authorizes licensed chiropractors to perform "chiropractic radiography," defined as the use of X-radiation for diagnostic purposes, without needing a separate certificate ⁸. The law also sets clear limitations and interprofessional requirements, such as mandating that chiropractic services for an animal may only be performed after a referral from a licensed veterinarian ¹². Additionally, the legislature has granted chiropractors specific public roles, including the authority under SDCL 36-5-15 to certify that a student is healthy enough to participate in high school athletics ¹⁶.

The South Dakota Board of Chiropractic Examiners (SDBCE) provides the second layer of governance by creating detailed regulations codified in the Administrative Rules of South Dakota (ARSD) under Title 20, Article 41. These administrative rules translate the broad principles of the statute into concrete, enforceable standards for daily practice. The SDBCE's authority includes defining professional conduct, setting continuing education requirements, and specifying procedures for licensure and certification. For instance, the board's rules on "unprofessional conduct" provide the primary mechanism for enforcing the statutory scope of practice. Under ARSD 20:41:10:05.02, engaging in conduct that falls outside the legally defined scope is a violation that can lead to disciplinary action ³. Therefore, while the legislature defines what chiropractic is, the board ensures that licensees adhere to that definition, protecting public safety by holding practitioners accountable for practicing within the established legal framework.

Core scope: chiropractic adjustment and manipulation

The central and defining function of chiropractic practice in South Dakota is the manual treatment of the human body's joints and associated tissues. State law establishes a foundational scope rooted in the profession's historical principles while providing specific definitions for its primary therapeutic procedures. South Dakota Codified Law (SDCL) 36-5-1 defines the practice of chiropractic as "the science of locating and removing the cause of any abnormal transmission of nerve energy including diagnostic and applied mechanical measures incident thereto" ¹. This statute explicitly authorizes chiropractors to engage in "treating of specific joints and articulations of the body and adjacent tissues" ^{1 20}. The primary methods sanctioned for this treatment are "manipulation, adjustment, and mobilization of a joint" ¹.

While the statute groups these terms, the South Dakota Board of Chiropractic Examiners (SDBCE) provides a precise technical definition for the profession's signature procedure. According to the board's administrative rules, a "chiropractic adjustment" is specifically defined as a passively applied movement of low amplitude and high-velocity thrust which moves a joint into the paraphysiological range ⁵. This high-velocity, low-amplitude (HVLA) thrust is distinct from the broader categories of manipulation and mobilization, which may involve different velocities and amplitudes of movement and do not necessarily involve moving a joint into the paraphysiological space. The inclusion of all three terms, "manipulation, adjustment, and mobilization," in the state's practice act grants chiropractors a spectrum of manual therapy techniques to address articular dysfunction ¹.

The legal language in SDCL 36-5-1, which refers to removing the cause of "abnormal transmission of nerve energy," directly reflects the founding tenets of the chiropractic profession ¹. D. D. Palmer, who established the practice in 1895, theorized that vertebral misalignments, which he termed subluxations, interfered with the nervous system's function and the body's innate healing capacity. The chiropractic adjustment was conceived as the method to correct these subluxations and restore normal nerve flow, a core concept that has been central to the profession's identity for generations ²¹.²²

Furthermore, the statutory authority to treat "adjacent tissues" confirms that the scope extends beyond the bones and joints to include the body's soft tissues ^{1 20}. This allows South Dakota chiropractors to apply manual procedures to the muscles, ligaments, tendons, and fascia that surround and support the articulations being treated. This integrated approach, which combines joint-focused adjustments with soft tissue work, is a standard component of modern chiropractic education and is detailed in clinical literature such as F. P. DeGiacomo's Textbook of chiropractic technique. This legal provision ensures that practitioners can address the full biomechanical complexity of a patient's condition, including myofascial restrictions and muscular imbalances that contribute to joint dysfunction.

Diagnostic authority: radiography and imaging

The authority for chiropractors to use diagnostic imaging is codified in South Dakota law, which defines "Chiropractic radiography" as "the application of X-radiation within the scope of practice of chiropractic for diagnostic purposes only" ⁸, ⁹. Licensed chiropractors are legally authorized to perform and interpret these procedures without needing a separate state certificate to do so ⁸. This diagnostic tool is considered integral to the practice of chiropractic, which involves "locating and removing the cause of any abnormal transmission of nerve energy" ¹. The use of plain film radiography allows practitioners to analyze skeletal alignment, identify congenital anomalies, assess for pathology, and evaluate biomechanical integrity before applying the "diagnostic and applied mechanical measures incident thereto" ¹. This practice aligns with the historical development of the profession, which emphasized objective means for identifying spinal misalignments, a central theme in foundational texts such as D. D. Palmer's The Chiropractor. The scope is strictly limited to diagnosis; radiation may not be used for therapeutic treatments ⁸.

South Dakota's regulatory framework distinguishes the authority of a licensed chiropractor from that of ancillary staff. While the state has specific training and registration requirements for chiropractic radiographers, the administrative rules explicitly exempt licensed chiropractors from these requirements ¹⁰. This exemption recognizes that comprehensive education in radiographic physics, patient positioning, safety, and image interpretation is a mandatory component of the curriculum at accredited chiropractic colleges. The chiropractor holds the ultimate responsibility for the radiographic study, from determining its clinical necessity to interpreting the findings. Under Colorado law, a chiropractic assistant may perform duties only under the direct supervision of a chiropractor and is prohibited from performing a diagnosis, an adjustment, or acupuncture. ²³, ²⁴. This structure ensures that the professional judgment required for radiographic procedures remains with the licensed doctor of chiropractic.

The operation of radiographic equipment in a chiropractic office is subject to specific safety and facility standards. While the South Dakota Board of Chiropractic Examiners' rules focus on personnel qualifications ¹⁰, regulations from the South Dakota Department of Health govern the physical environment and equipment. A chiropractic facility utilizing X-ray technology must have a dedicated radiographic room of at least 80 square feet ²⁵. For operator safety, this room must be equipped with a shielded control booth that protects staff from scatter radiation during an exposure ²⁵. Furthermore, all radiographic equipment is required to be inspected and formally registered with the Department of Health ²⁵. Compliance with these health and safety regulations is mandatory. Failure to maintain a properly configured and registered facility or to adhere to radiation safety protocols could be considered unprofessional conduct, potentially subjecting the chiropractor to disciplinary action from the Board of Chiropractic Examiners for failing to maintain proper patient records or engaging in practice outside the scope of chiropractic ³, ⁴.

Adjunctive therapies: physiotherapy and nutritional counseling

The scope of chiropractic practice in South Dakota extends beyond the specific joint adjustment to include a range of supportive therapeutic procedures ¹. This authority is rooted in the state’s legal definition of chiropractic, which encompasses "diagnostic and applied mechanical measures" used to treat articulations and their "adjacent tissues" ¹. The South Dakota Board of Chiropractic Examiners explicitly authorizes practitioners to use a variety of physiotherapeutic measures, including the application of heat, cold, exercise, and mechanical forces as part of a patient's treatment plan ⁶.

While the state’s administrative rules do not provide an exhaustive list of every permitted modality, the authorization for their use is strongly implied in the rules governing ancillary personnel. South Dakota Administrative Rule 20:41:15:01, which outlines the curriculum for registered chiropractic assistants, mandates training in "introduction to physiotherapy, use of modalities, rehabilitation and exercise programs as designed by the chiropractor" ⁷. Because assistants may only perform these tasks under the direct supervision of a licensed chiropractor, this provision substantiates the chiropractor’s primary authority to design and administer these therapies ²³. The use of such modalities to address the soft tissue components of joint dysfunction is a standard element of chiropractic education and is detailed in clinical manuals like F. P. DeGiacomo's Textbook of chiropractic technique. These therapies are employed to reduce pain, decrease inflammation, improve circulation, and restore normal function to muscles and ligaments, complementing the effects of the chiropractic adjustment.

Similarly, the authority for chiropractors to provide nutritional counseling is implicit in the state’s regulatory framework. The South Dakota chiropractic practice act and its associated administrative rules do not contain specific language authorizing nutritional advice or the sale of dietary supplements ¹⁵. Instead, the scope is defined to include therapeutics that are taught in approved chiropractic colleges ¹⁵. Curricula at institutions accredited by the Council on Chiropractic Education, the national standard for licensure, include extensive coursework in biochemistry, clinical nutrition, and dietetics. This educational foundation grants chiropractors the implicit authority to advise patients on diet and nutritional supplementation as it relates to their overall health and the structural integrity of the body. This approach aligns with the profession's historical focus on addressing the underlying causes of disease, including chemical and metabolic stressors, a concept central to the philosophy of developers like D. D. Palmer ²¹. Consequently, South Dakota chiropractors may recommend dietary changes and the use of vitamins or minerals to support musculoskeletal health. While the sale of supplements is a common extension of this advisory role, practitioners must ensure their conduct remains professional and that they do not make therapeutic claims that could be considered misleading or outside their scope of practice ³.

Extended practices requiring certification: acupuncture

In South Dakota, the practice of acupuncture by a chiropractor is considered an extended practice that requires specific certification beyond the standard chiropractic license. While the core scope of chiropractic focuses on the science of locating and removing the cause of abnormal nerve energy transmission through mechanical measures like adjustment and mobilization ¹, the use of acupuncture necessitates additional, specialized training and demonstrated competency. This regulatory framework ensures that practitioners who incorporate this modality into their services have met a uniform standard of proficiency as defined by the South Dakota Board of Chiropractic Examiners. The requirement for a separate certification distinguishes acupuncture from other adjunctive therapies that may be considered inherent to or an extension of standard chiropractic education.

The primary gateway for a licensed South Dakota chiropractor to legally perform acupuncture is the successful completion of the acupuncture examination administered by the National Board of Chiropractic Examiners (NBCE) ¹¹. The NBCE is the principal testing agency for the chiropractic profession in the United States, and its examinations are used by licensing authorities to assess the knowledge and skills of candidates for licensure and specialized practices. To be eligible for the acupuncture certification, a chiropractor must provide the South Dakota board with official proof of having passed this specific NBCE examination ¹¹. This requirement establishes a national, standardized benchmark for minimum competency, ensuring that practitioners possess the foundational knowledge of acupuncture theory, meridian pathways, point location, clean needle technique, and contraindications. The process is not merely a formality; it represents the culmination of a significant post-graduate course of study, typically consisting of at least 100 hours of dedicated classroom and practical instruction, which prepares the candidate for the rigorous NBCE assessment.

Once a chiropractor has obtained the initial certification, its maintenance is contingent upon meeting ongoing continuing education (CE) requirements. The South Dakota Administrative Rules mandate that a chiropractor holding an acupuncture certification must complete eight hours of CE specifically in the field of acupuncture during each two-year license renewal cycle ²⁶. These hours are part of, not in addition to, the total CE hours required for license renewal, but they must be dedicated solely to acupuncture-related topics. This provision ensures that certified practitioners remain current with evolving techniques, new research findings, and safety protocols within the discipline. Failure to acquire and document these eight specialized hours can result in the non-renewal of the acupuncture certification, even if the general chiropractic license is maintained. Performing acupuncture without a valid, current certification is deemed unprofessional conduct and a violation of the state's practice act, which can subject the licensee to disciplinary action by the board, including fines or suspension ³.

Specialized scope: animal chiropractic

The practice of animal chiropractic in South Dakota is a specialized field governed by a dual-layered regulatory framework that mandates both advanced certification and interprofessional collaboration. Unlike the primary scope of practice focused on human patients, a chiropractor must meet specific, stringent requirements before legally providing services to animals ²⁷. This structure ensures that animal care is delivered by qualified individuals working within a medically supervised context. The first layer of this framework is an educational and credentialing requirement enforced by the South Dakota Board of Chiropractic Examiners. According to the state's administrative rules, a chiropractor must first complete a board-approved postgraduate course in animal chiropractic ¹³. This program must consist of a minimum of 210 hours of dedicated study. Upon successful completion of this extensive training, the practitioner must also pass a competency examination approved by the Board ¹³. Only after fulfilling these educational and testing prerequisites can a chiropractor apply for and receive a formal certificate in animal chiropractic from the Board, which is the legal authorization to practice in this specialty area ²⁷. While foundational chiropractic principles were developed for human application, as detailed in historical texts like D.D. Palmer's The Chiropractor, the 210-hour curriculum provides essential, species-specific knowledge in areas such as comparative neuro-musculoskeletal anatomy, animal biomechanics, and safe adjusting techniques for non-human patients.

The second layer of the regulatory structure is an operational mandate that requires direct cooperation with the veterinary profession on a case-by-case basis. Even after obtaining the necessary certification, a South Dakota chiropractor is not permitted to independently treat an animal patient. State law, specifically South Dakota Codified Law (SDCL) 36-5-19, dictates that a chiropractor may only perform chiropractic services on an animal upon receiving a direct referral from a licensed veterinarian ¹². This is not a one-time, blanket authorization but a prerequisite for each individual animal seeking care ²⁸. The statute further clarifies that the referring veterinarian must have first established a formal veterinarian-client-patient relationship (VCPR) ¹². This legal and ethical standard means the veterinarian has personally examined the animal, assumed responsibility for making clinical judgments regarding its health, and is available for follow-up evaluation. This referral requirement positions the chiropractor as a specialist provider working in a consultative capacity under the primary diagnostic and medical oversight of the veterinarian. Failure to adhere to either of these requirements, such as practicing animal chiropractic without the 210-hour certification or treating an animal without a valid veterinary referral, places the chiropractor outside their legal scope of practice and constitutes unprofessional conduct, which may lead to disciplinary action by the Board ³.

Prohibitions, limitations, and professional conduct

The South Dakota Board of Chiropractic Examiners is tasked with enforcing the boundaries of the profession, with specific statutes and administrative rules defining prohibited acts and outlining standards for professional conduct ³. Engaging in practices outside the legally defined scope, or violating established professional ethics, can result in disciplinary action, including license suspension or revocation. A significant limitation within the South Dakota chiropractic scope of practice is the prohibition against performing dry needling. Neither the state's chiropractic practice act, South Dakota Codified Law (SDCL) Chapter 36-5, nor the Board's administrative rules explicitly authorize chiropractors to perform this procedure ². The practice is therefore considered outside the scope for chiropractors, a status reinforced by its explicit authorization for other licensed professionals, such as physical therapists ¹⁴. A chiropractor performing dry needling would be engaging in conduct outside their scope of practice, an act specifically identified as unprofessional conduct ³.

The South Dakota Administrative Rules of South Dakota (ARSD) 20:41:10:05.02 provide a detailed list of actions that constitute unprofessional or dishonorable conduct ³. Beyond practicing outside the legal scope, these actions include failing to maintain adequate and accurate patient records for a minimum of six years from the date of the last patient visit ⁴. Chiropractors are also prohibited from failing to cooperate with a board inquiry or investigation, which is considered a direct violation of professional duty ⁴. The Board also defines unprofessional conduct to include the failure to properly supervise ancillary staff. This is particularly relevant to the use of chiropractic assistants, who must be under the "direct supervision" of a licensed chiropractor ²³. This standard requires the personal presence and availability of the supervising chiropractor at the facility where services are being rendered by the assistant ²³.

Fundamental prohibitions, rooted in the profession's historical development and statutory definitions, also apply. The scope of practice in SDCL 36-5-1 is centered on "the science of locating and removing the cause of any abnormal transmission of nerve energy including diagnostic and applied mechanical measures" ¹. This definition inherently excludes practices considered the practice of medicine, such as prescribing legend drugs or performing incisive surgery. These limitations reflect the core principles established by early chiropractic figures like D.D. Palmer, who positioned the profession as a non-surgical, drug-free healing art. Furthermore, while chiropractors may delegate certain ancillary services to registered chiropractic assistants, they are expressly prohibited from delegating core professional responsibilities. Under Oregon administrative rules, a chiropractic assistant may not perform physical examinations, take initial histories, interpret postural screening, perform manual muscle testing, or perform osseous adjustments or manipulations. ²⁴.

Delegation, supervision, and ancillary responsibilities

In South Dakota, licensed chiropractors function as clinical supervisors, holding ultimate responsibility for all patient care delivered within their practice. This includes the delegation of certain ancillary services to qualified staff. The primary personnel for such delegation are Registered Chiropractic Assistants (RCAs), who must complete a board-approved educational program before they can perform any delegated tasks ²⁴. While a chiropractor may delegate ancillary duties, they may not delegate core professional responsibilities. The supervising chiropractor remains legally and ethically accountable for all services rendered, including those performed by an assistant.

The scope of tasks that an RCA may perform is strictly defined and limited. Assistants are explicitly prohibited from engaging in any activity that requires the professional skill and judgment of a licensed chiropractor. These forbidden tasks include evaluating a patient's condition, interpreting diagnostic findings, designing an initial treatment program, or modifying an existing plan of care ²⁴. All duties performed by an RCA must be conducted under the "direct supervision" of the licensed chiropractor ²³. The South Dakota Board of Chiropractic Examiners, in Administrative Rule 20:41:15:10, defines "direct supervision" as the personal presence and immediate availability of the supervising chiropractor at the physical location where the services are being provided ²³. This on-site requirement ensures that the chiropractor can intervene and provide guidance at any moment. Failure to provide this level of supervision is considered unprofessional conduct and may lead to disciplinary action against the chiropractor's license ⁴.

Beyond the confines of the clinic, the scope of practice in South Dakota grants chiropractors significant responsibilities that overlap with primary care roles, particularly in the context of athletics and occupational health. Under South Dakota Codified Law 36-5-15, chiropractors are authorized to perform physical examinations and subsequently certify that a patient is healthy and cleared for participation in high school or other athletic activities ¹⁶. This authority allows chiropractors to serve as gatekeepers for student-athlete safety, assessing musculoskeletal and neurological fitness before the start of a sports season.

Complementing this authority, SDCL 36-5-15.3 empowers chiropractors to withdraw a patient from a work or athletic activity if a health-related reason makes continued participation unsafe ¹⁷. This statute gives chiropractors the legal standing to issue binding medical restrictions for both employees and athletes. For instance, a chiropractor can require an employer to place an injured worker on light duty or mandate that a school remove a student-athlete from competition following a concussion or other injury. This authority to both certify fitness and restrict activity underscores the chiropractor's recognized role in managing patient health, recovery, and safe return to daily life in South Dakota ¹⁷.

Sources

1. South Dakota Codified Law 36-5-1 - https://sdlegislature.gov/Laws/Codified_Laws/20496

2. South Dakota Codified Law Chapter 36-5 - https://sdlegislature.gov/Laws/Codified_Laws/20495

3. South Dakota Codified Law 36-35-6.1 - https://sdlegislature.gov/Laws/Codified_Laws/2047866

4. N.Y. Comp. Codes R. & Regs. Tit. 8 § 29.2(a)(3) - General provisions for health professions - https://www.law.cornell.edu/regulations/new-york/NY-Comp-Codes-R-Regs-Tit-8-29-2

5. South Dakota Administrative Rules 20:41:01:02 - https://sdlegislature.gov/Rules/DisplayRule.aspx?Rule=20:41:01:02

6. Practice Analysis of Chiropractic, 2020 - https://www.nbce.org/practice-analysis-of-chiropractic-2020/

7. South Dakota Administrative Rules 20:41:15:01 - https://sdlegislature.gov/Rules/DisplayRule.aspx?Rule=20:41:15:01

8. South Dakota Codified Law 36-5-1.1 - https://sdlegislature.gov/Laws/Codified_Laws/20497

9. South Dakota chiropractors are permitted to perform chiropractic radiography, which is the application of X-radiation for diagnostic purposes only. - https://sdlegislature.gov/Laws/Codified_Laws/Display/20497

10. South Dakota Administrative Rules 20:41:13:10 - https://sdlegislature.gov/Rules/DisplayRule.aspx?Rule=20:41:13:10

11. South Dakota Board of Chiropractic Examiners, Continuing Education Requirements - https://doh.sd.gov/boards/chiropractic/continuingeducation.aspx

12. Minnesota Statutes 148.032, Animal Chiropractic - https://www.revisor.mn.gov/statutes/cite/148.032

13. Arizona Administrative Code R4-7-603, 2016 - https://apps.azsos.gov/public_services/Title_04/4-07.pdf

14. The South Dakota chiropractic practice act and the Board's administrative rules do not explicitly authorize chiropractors to perform dry needling; this procedure is authorized for physical therapists. - https://sdlegislature.gov/Laws/Codified_Laws/Display/20495

15. South Dakota Administrative Rules 20:41:01:01(5) - https://sdlegislature.gov/Rules/DisplayRule.aspx?Rule=20:41:01:01

16. South Dakota Codified Law 36-5-15 - https://sdlegislature.gov/Laws/Codified_Laws/20511

17. South Dakota Codified Law 36-2-16.2 - https://sdlegislature.gov/Laws/Codified_Laws/20511

18. Chiropractic in America: The History of a Medical Alternative, 1993 - https://www.press.jhu.edu/books/title/299/chiropractic-america

19. Russell W. Gibbons, Chiropractic history (1977) - https://openlibrary.org/works/OL5541722W

20. South Dakota Codified Law 36-5-1 - https://sdlegislature.gov/Laws/Codified_Laws/Display/20496

21. The secret history of chiropractic by Simon A. Senzon (2005) - https://openlibrary.org/works/OL9914472W

22. Walter I. Wardwell, Chiropractic (1992) - https://openlibrary.org/works/OL4280776W

23. Colorado Revised Statutes Section 12-215-128 (2025) - https://law.justia.com/codes/colorado/2023/title-12/article-215/part-1/section-12-215-128/

24. Oregon Secretary of State, 2024 - https://sos.state.or.us/archives/pages/rules/oars_800/oar_811/811_010.html

25. 902 KAR 20:101. Facility specifications; ambulatory surgical center. - https://apps.legislature.ky.gov/law/kar/902/020/101.pdf

26. South Dakota Administrative Rules 20:41:08:02 - https://sdlegislature.gov/Rules/DisplayRule.aspx?Rule=20:41:08:02

27. Minnesota Board of Chiropractic Examiners, Animal Chiropractic Registration Requirements - https://mn.gov/boards/chiropractic-examiners/licensure/animal-chiropractic/

28. A licensed chiropractor in South Dakota may perform chiropractic services on an animal only upon referral from a licensed veterinarian. - https://sdlegislature.gov/Laws/Codified_Laws/Display/20515