Hoefer v. Snellgrove
In Hoefer v. Snellgrove, 48 Ala. App. 11, 15, 261 So. 2d 426, 429 (1971), rev'd on other grounds, 288 Ala. 407, 261 So. 2d 431 (1972) the trial court had excluded the chiropractor's testimony of his opinion about the permanency of the patient-plaintiff's back injury and about the residual effects of his back injury.
The rationale of the trial court was that the chiropractor was not qualified, and that the medical doctor who treated the plaintiff was more qualified, to testify about these matters. Hoefer, 48 Ala. App. at 14, 261 So. 2d at 428.
Reversing the trial court, the Court of Civil Appeals held that a qualified chiropractor could testify as an expert about the extent and the permanency of his patient's injury and about the present and future treatment of his patient. Id.