—corporation that established a fixed fee, low cost medical clinic in Chicago in which all services were rendered by licensed physicians, whom the corporation paid, may not practice learned professions and may not do so by employing licensed physicians

—a corporation's ownership of a medical clinic with offices in which patients were treated solely by licensed and registered physicians employed by the corporation, and which received the fees charged the patients, constituted the practice of medicine by the corporation within the meaning of a statute that prohibited such practice except by licensed persons.

Cases applying a common law prohibition on corporate practice have addressed health care fields such as medicine, dentistry, optometry, and chiropractic.

In 1936, the Supreme Court held that the state' s CPOM doctrine prevents for-profit hospitals from employing physicians

Courts that base a prohibition against the corporate practice of medicine on an interpretation of the state medical practice act find that because a corporation cannot meet the personal qualifications23 of the licensure statute, it may not practice medicine

The legislative intent manifest from a view of the entire [Medical Practice Act] is that only individuals may obtain a license thereunder. No corporation can meet the requirements of the statute essential to the issuance of a license

—pointed out that the Medical Practice Act contains no express prohibition on the corporate employment of physicians. "'Rather, the doctrine was inferred from the general policies supporting the Act."

Despite the argument that corporate employment of physicians does not change the professional relationship between the patient and medical practitioner, and does not constitute the practice of medicine, the court in United Medical Service held that such arrangements were necessarily prohibited.