Abstract

The Supreme Court of Idaho held, in Idaho Association of Chiropractic Physicians, Inc. v. Alcorn, No. 23787,1999 WL 134677, at *1, that insurance regulations of health care services must apply equally to all providers. The Idaho legislature enacted the Small Employer Health Insurance Availability Act, Idaho Code § 41-4701, and the Individual Health Insurance Availability Act, id. § 41-5201, which is to be implemented by the Idaho Small Employer and Individual Health Reinsurance Program. The goal of the legislation is to make health insurance available and affordable to small employers and their employees, and to individuals who would not otherwise have health insurance. Accordingly, the Program promulgated the following rule: “Chiropractic services will be subject to one thousand dollars per year limit.” Idaho Ass’n of Chiropractic Physicians, 1999 WL 134677, at *1.The plaintiff, the Idaho Association of Chiropractic Physicians, sought declaratory judgment and injunctive relief against defendant, James M. Alcorn, director of the Idaho State Department of Insurance, on equal protection and due process grounds.