In Cartwright v. Board of Chiropractic Examiners (1976) 16 Cal.3d 762, the court held that a nolo contendere plea could not be used against a licensee in a disciplinary proceeding under the Chiropractic Act. While that holding in that case was abrogated by constitutional amendment, the court explained why such a plea must be viewed cautiously. "The conviction is significant in the statutory scheme only insofar as it is a reliable indicator of actual guilt. When the conviction rests on the verdict or finding of a trier of fact after trial, it means that guilt has been established beyond a reasonable doubt, and when the conviction rests on a plea of guilty, it means that the defendant has voluntarily admitted guilt for all purposes. But when the conviction is based on a nolo contendere plea, its reliability as an indicator of actual guilt is substantially reduced, both because of the defendant's reservations about admitting guilt for all purposes and because the willingness of the district attorney to agree to and the court to approve the plea tends to indicate weakness in the available proof of guilt. " ( Id. at p. 773.) As Cartwright stated, the purpose of the Chiropractic Act "is not merely to single out persons who have been the subject of certain procedural formalities but to reach those who have actually committed the underlying offenses." ( Cartwright v. Board of Chiropractic Examiners, supra, 16 Cal.3d at p.773.)