McNaughton v. Johnson
Headline: California law requiring state registration for optometrists is upheld, and the Court affirmed denial of a court order preventing enforcement so the state can require certificates for vision examiners.
Holding:
- Allows California to enforce optometry registration and licensing requirements.
- Unregistered vision-measuring practitioners face misdemeanors, fines, and possible imprisonment.
- Practitioners using different training names must obtain state certification to avoid penalties.
Summary
Background
A Los Angeles eye specialist who measures vision without using drugs challenged a California law that makes it illegal to practice optometry without a state certificate. The statute defines optometry as measuring vision by any means other than drugs, sets up a state board to examine and register optometrists, and makes violations misdemeanors with fines and imprisonment. The law also exempts licensed physicians and allows the sale of ready-to-wear glasses from ordinary stores.
Reasoning
The main question was whether the State could require certification for people who measure vision without drugs. The complainant argued the law violated the Constitution’s guarantee of due process and equal treatment by favoring those who use drugs or who have different professional names. The Court relied on prior decisions saying states may regulate the practice of medicine and concluded the complainant had not shown a tangible, unlawful discrimination beyond a difference in names or training. On those facts, the Court agreed the lower court correctly refused a temporary order that would have blocked enforcement.
Real world impact
Because the injunction was denied and the decree affirmed, California may continue to enforce its registration requirement and penalize unregistered vision examiners while legal challenges proceed. The ruling allows the state board to examine and register optometrists, and practitioners who measure vision without a certificate risk criminal penalties. The opinion leaves open any later, full trial on the law’s merits.
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