From January 14-16, the annual Parker Seminars Las Vegas event generated a palpable energy that coursed through the veins of over 4000 attendees, making it one of the most powerful conference/tradeshows available to Dcs, all over the world. This major continuing education event, which also showcased the contributions of hundreds of products and services to the profession of chiropractic, featured an impressive roster of speakers who taught to overflowing rooms on a wide variety of relevant and timely topics. Topics included aspects of immune system health, pillars of evidence-based wellness care, elements of paediatric chiropractic practice, considerations for patient confidentiality, embracing science along with philosophy in chiropractic, practice building and management strategies to use on Monday morning, rehabilitation education and more. There were also many sessions available for chiropractic health assistants (CHAs). CHA topics ranged from practice administration points to patient education and were all skillfully tied together with a focus on a leadership mindset that CHAs could embrace in their support roles within chiropractic clinics around the world. The three day event included many opportunities for Dcs, chiropractic students and CHAs to discover more about their own potential while networking with other chiropractic professionals from all over North America and globally. (Of note, were the constant observations that Canadians seemed to attend this event, this year, in greater numbers than ever before.) The Friday night gala was enjoyable, and provided an outlet for attendees to kick back and relax together, before moving on to another day of content-rich sessions. President of Parker College of Chiropractic and Parker Seminars, Dr. Fabrizio Mancini, was, of course, on hand to inspire attendees at the opening and closing ceremonies, as well as throughout the event. Vice president, Development and External Relations, at Parker College of Chiropractic (and Canadian DC) Dr. Gilles Lamarche, constantly encouraged attendees toward full commitment to their practices and patients.Of note also, NFL hero Jerry Rice and U.S. retired Brigadier General, Becky Halstead, presented to attendees and offered autograph signing and photo opportunities. Their presence was a vote of support for the profession not only as a whole, but by way of thanks for what chiropractic has done for them. There is no doubt that this conference and trade show were a huge success but, more importantly, it was inspiring to see the levels of professional and personal commitment, in organizers, presenters and attendees alike. Parker College of Chiropractic continues to hold a roster of events and extends its next invitation to Parker Seminars, Montreal, which will be held from May 20-22, 2010 at the Hilton Bonaventure Hotel in the heart of that beautiful Canadian city. For more information and registration details, please visit www.parkerseminars.com. Ne w Editorial Advisory Board Me mbe r Canadian Chiropractor welcomes Dr. Wanda Lee MacPhee Wanda Lee MacPhee, Bsc, DC, has been in chiropractic practice in Nova Scotia since 1994. A graduate of CMCC, she has started a practice, sold a practice and joined an existing practice at St. Margaret’s Bay Chiropractic with her husband, Dr. Andrew Kleinknecht. Along the way, she has gained a wealth of experience in all aspects of chiropractic practice systems and management. The mother of two young children, Claire and Thomas, Dr. MacPhee now practises part time but manages to donate many hours to the profession. Dr. MacPhee has been registrar, chair of the board and association president in Nova Scotia as well as the president of the Canadian Federation of Chiropractic Regulatory and Educational Accrediting Board (CFCREAB), and is a current member of the Clinical Practice Guidelines Task Force. In 2000, Dr. MacPhee was honoured as Chiropractor of the Year in Nova Scotia. In 2008, she was named an honorary director in the CFCREAB and, that same year, was also recognized with the Award of Merit from the Canadian Chiropractic Association. Her respect for the incredible benefits and services that chiropractors offer the world continues to drive her toward helping other chiropractors achieve their optimal level of life and practice success. In 2006, Dr. MacPhee – along with Dr. Kleinknecht – founded Chiropractic AudioCoach Teleseminars. The goal behind this venture is to bring the best business, practice and personal development experts to chiropractors via the Internet. Dr. MacPhee also offers personal consulting, team-building programs and strategic planning workshops for chiropractors and chiropractic organizations, and has organized a number of events designed to bring the wealth of knowledge that exists in our profession to all chiropractors who are seeking to learn and grow. Outside of chiropractic, Dr. MacPhee enjoys travel, reading, sunshine and spending time with her family and friends – especially if good food and wine are involved! Albe rta court denies class act ion against ACAC In Reasons for Judgment released on January 11, 2010, Mr. Justice R. Paul Belzil of the Alberta Court of Queen’s Bench denied certification of the class action launched against the Alberta College and Association of Chiropractors (ACAC). ACAC was very competently represented by legal counsel from the firm Branch MacMaster: Jim MacMaster, Ward Branch, and Don Lebans. ACAC was victorious on every issue. Justice Belzil found the proposed class action against ACAC to be unworkable on all aspects of the legal test for certification. The decision is significant not only for ACAC and chiropractors in Alberta but for all Canadian professional regulatory bodies and the professionals they regulate. No private law duty of care Most importantly, Justice Belzil determined that that it was “plain and obvious” that there was not a “cause of action” against ACAC which means there was no valid legal basis for suing ACAC. In coming to this determination, Justice Belzil confirmed that, under the Alberta Health Professions Act, ACAC’s responsibility in governing the chiropractic profession is to the public as a whole, and not to any individual patient. He also noted the total absence of any dealings between ACAC and those suing which might otherwise have given rise to a duty to be mindful of their personal interests. Further Justice Belzil found that making a health care regulator such as ACACresponsible for individual patients was contrary to ACAC’s public protection mandate and the policy decisions ACAC must make in fulfilling that mandate: As noted, the [Health Profession Act] established legislative authority over chiropractic within the Province, which must necessarily involve policy decisions. Imposing private law duties of care on regulators would interfere with their ability to make decisions considering the needs of the public at large. The decision reinforces the general principle that the potential for liability of professional regulatory bodies should be quite limited. Courts not proper forum to settle scientific disputes Justice Belzil refused to recognize a cause of action in relation to the allegation that the practice of chiropractic is based on a flawed scientific foundation. Citing legal precedent including other cases involving chiropractic institutions (Lewis v. Emmanuele and Corvaro v. Canadian Memorial Chiropractic College) where the attempt to attack the scientific foundation of chiropractic was unsuccessful, Justice Belzil found that this allegation was “nothing more than an attempt to resolve a scientific dispute in a court of law, and would also amount to an attack on the legislative competence of the Province in enacting the HPA.” This decision serves as additional strong support for the principle that courts are not the proper forum to settle scientific disputes. Other criteria for certification not satisfied Justice Belzil also concluded that there was a failure, on the part of the plaintiffs to define a class of people who were similarly affected by any actions of ACAC, calling their proposed definition “too vague and thus unworkable”. In a similar vein, he denied the existence of any issues that were common to all of the people the plaintiffs had hoped would fit within that definition, noting the inherent individuality of chiropractic care, including the different types and duration of treatment that may be provided, the varying techniques that can be used in providing those treatments, and the individualized information communicated to the patient. Justice Belzil found that a class proceeding was not the preferable procedure. He also expressed a concern as to whether the individuals who had requested the class action were not appropriate representative plaintiffs. Summary The attempt to certify a class action against ACAC in relation to its regulation of chiropractic and against all individual chiropractors in Alberta for alleged inappropriate and nonbeneficial treatment has been defeated. ACAC will monitor the action to see if an appeal is taken. The plaintiffs did not appeal the July 2009 decision which dismissed their claim against the Alberta government. This is an important victory for regulatory bodies and the chiropractic profession. At the general level, the judgment reinforces that regulatory bodies do not owe a specific private law duty of care to individuals except in exceptional circumstances. Furthermore, the judgment supports the theme that it is not appropriate to attack the scientific validity of chiropractic in the courts. This decision will help to limit the legal options of the anti-chiropractic lobby