Martin Hart

Complaint template prepared from a public-record review by drtrustmebro.com. The complaint you submit is your own; review and edit every statement before signing. This template is intended for residents or patients of Tennessee. It is not legal advice.

In the Matter of:
Martin Hart
License No. [LICENSE NUMBER, IF KNOWN]
506 North High Street, Columbia, Tennessee, 38401
NPI (public registry): 1275944506

I. INTRODUCTION

Complainant respectfully submits this complaint to the TENNESSEE BOARD OF CHIROPRACTIC EXAMINERS requesting formal investigation and regulatory review concerning Martin Hart (the Respondent), identified in the attached public materials.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including PANS/PANDAS, Hashimoto's thyroiditis, rheumatoid arthritis, lupus, Mold Illness (CIRS), and Lyme Disease, that may extend beyond the D.C. scope in Tennessee.

Public registry records associate the Respondent's licensure with Oregon, while the practice location described in the public materials is in Tennessee. This complaint is directed to the board for the state where the practice is publicly advertised. The licensing authority in Oregon may also accept a complaint concerning the same conduct.

This complaint is based exclusively upon publicly available materials and does not rely upon confidential patient records, privileged communications, or non-public investigative information. The factual observations herein were assembled from an automated public-record review of the Respondent's public website and public registry records, and were reviewed and adopted by the Complainant. All observations are potential, unverified signals from public records; the Board is the sole finder of fact.

The principal public materials reviewed include https://keystonefunctionalhealth.com/ and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Scope of Practice Concerns

Public content appears to address PANS/PANDAS, Hashimoto's thyroiditis, rheumatoid arthritis, lupus, Mold Illness (CIRS), Lyme Disease, MCAS & Histamine Issues, Autoimmunity, Chronic Fatigue, Mold illness and CIRS, Lyme disease and co-infections, and Autoimmune and immune dysregulation, which the applicable licensing rules suggest may fall outside the D.C. scope in Oregon.

B. Complainant's Own Experience

[DESCRIBE YOUR OWN EXPERIENCE, IF ANY]

III. AREAS OF CONCERN

COUNT I: PRACTICING BEYOND THE LAWFUL SCOPE OF CHIROPRACTIC

Cited authority: T.C.A. Section 63-4-101 and Rule 0260-02-.02.

The public materials described in the Statement of Facts above appear to address PANS/PANDAS, Hashimoto's thyroiditis, rheumatoid arthritis, lupus, Mold Illness (CIRS), Lyme Disease, MCAS & Histamine Issues, Autoimmunity, Chronic Fatigue, Mold illness and CIRS, Lyme disease and co-infections, and Autoimmune and immune dysregulation, which the cited rule text suggests may fall outside the D.C. scope.

The conduct described above raises substantial concerns under T.C.A. Section 63-4-101 and Rule 0260-02-.02 and warrants Board investigation.

COUNT II: DECEPTIVE AND MISLEADING CONDUCT

Cited authority: Rule 0260-02-.13(1) and T.C.A. Section 63-1-123.

The conduct described above raises substantial concerns under Rule 0260-02-.13(1) and T.C.A. Section 63-1-123 and warrants Board investigation.

COUNT III: MISREPRESENTATION OF PROFESSIONAL STATUS AND TITLE

Cited authority: Rule 0260-02-.03.

The conduct described above raises substantial concerns under Rule 0260-02-.03 and warrants Board investigation.

COUNT IV: EXCESSIVE EXAMINATIONS AND TREATMENT

Cited authority: Rule 0260-02-.13(5) and 0260-02-.13(6).

The public materials described above appear to present condition-specific frameworks, laboratory-testing guidance, and treatment protocols directed at systemic conditions, rather than services grounded in the licensed scope.

The conduct described above raises substantial concerns under Rule 0260-02-.13(5) and 0260-02-.13(6) and warrants Board investigation.

COUNT V: USE OF UNLICENSED ASSISTANTS

Cited authority: Rule 0260-02-.13(9).

The conduct described above raises substantial concerns under Rule 0260-02-.13(9) and warrants Board investigation.

IV. RELIEF REQUESTED

A. Formal investigation of the conduct described herein, including review of the Respondent's public advertising, website representations, consultation materials, and commercial structures.

B. A determination by the Board of whether the conduct described herein is consistent with the statutes and rules cited above.

C. Such disciplinary action as the Board deems appropriate based on its own investigation and findings, up to the maximum authorized for any violation the Board finds.

D. Corrective relief, where the Board deems appropriate, including requiring the Respondent to correct or remove the specific public representations described above and, if the conduct continues, seeking injunctive relief through a court of competent jurisdiction.

E. To the extent within the Board's authority, review of the revenues derived from the consultations, care plans, and product sales described above, and consideration of restitution for consumers who relied on the representations to their financial or physical detriment.

F. Such other and further relief as the Board deems just and proper to protect the public.

Respectfully submitted,

[YOUR NAME]

[YOUR MAILING ADDRESS]

[YOUR EMAIL AND PHONE]

[DATE]

EDIT BEFORE SENDING

1. Confirm the license number using the license lookup in Exhibit A and fill it in on page 1.
2. Replace every bracketed placeholder with your own information, or delete sections that do not apply.
3. Print and attach dated captures of each exhibit page listed in the exhibit index.
4. Review every factual statement yourself before signing; submit only what you can stand behind.
5. Check the board's current submission rules (online portal, mail, or fax) before sending.
6. Public registry records also associate the licensure with Oregon; consider sending a copy of this complaint to that state's board as well.

EXHIBIT INDEX