Crane v. Johnson
Headline: Court allows California to enforce licensing rules for healing practices, denies temporary block, making it harder for non-prayer drugless healers to avoid state exams and licenses.
Holding: The Court declined to stop enforcement of California’s licensing law, holding the complaint’s allegations did not justify an injunction and that the State may treat prayer-based healing differently from other drugless practices.
- Allows state exams and licenses to remain enforceable against non-prayer healers.
- Makes it harder for non-religious drugless practitioners to avoid licensing requirements.
- Denial is temporary, not final; outcome could change on full review.
Summary
Background
A Los Angeles drugless healer who uses faith, mental suggestion, and mental adaptation sued to stop a California law that creates state medical exams and licenses. The law sets different certificates for physicians, drugless practitioners, and chiropodists and exempts treatments that are purely prayer or religious practice. The healer says the law unfairly treats his non-prayer methods worse than prayer-based healing and therefore violates the Fourteenth Amendment’s equal protection guarantee. He asked the court for an early injunction to prevent enforcement while the case proceeds.
Reasoning
The Court reviewed only the complaint’s allegations and the narrow question of whether those allegations justified an immediate injunction. It said the State could reasonably view the complainant’s method as a skill-based healing that requires diagnosis and training, while treating prayer as a religious practice. The Court concluded the complaint did not demonstrate that the distinction was arbitrary or that an injunction was warranted. For that reason, the Court denied the requested relief and affirmed the lower court’s order.
Real world impact
The ruling lets California continue enforcing its licensing and exam rules against non-prayer drugless practitioners for now. It means healers who do not use prayer may have to meet state education and testing requirements or face penalties. The opinion is limited to the early injunction request and is not a final decision on the law’s ultimate legality; the final outcome could change on full review.
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