In Gibson v. Berryhill (1973) 411 U.S. 564, the Supreme Court held that the question of whether licensed optometrists could be employed by business corporations could not be decided by an optometry board composed of licensed optometrists who were independent contractors. The court reasoned that if employment of optometrists by corporations were outlawed, the members of the board might acquire some of the business which had previously gone to the corporations. It was held that this potential for additional business gave the board members a sufficient personal interest in the matter to render them biased. Holding that the laws concerning disqualification for interest applicable to judicial officers apply with equal force to administrative adjudicators, and that "interest' need not be a direct financial stake in the outcome of the litigation (411 U.S. p. 579), the court stated that the standard was not whether the board members were actually biased, but whether the facts indicated a possible temptation toward bias for the average man sitting as a judge. (411 U.S. p. 571.)