Administrative Law Judge's Conclusions
about Hal A. Huggins, D.D.S.

Stephen Barrett, M.D.


In 1995, the Colorado State Board of Dental Examiners held twelve days of hearings related to complaints brought against Hal Huggins. On February 29, 1996, Administrative Law Judge Nancy Connick recommended that Huggins's license should be revoked for gross negligence and other professional misconduct. Huggins did not appeal, and his license was subsequently revoked. The judge's report contained 235 findings of fact, of which 21 are reproduced below, followed by the full text of the judge's conclusions and decision. Huggins's license was revoked in 1996. In 2007, the Board concluded that Huggins was engaging in the unlawful practice of dentistry by providing services in a dental clinic that he owned. Huggins denied the Board's allegations but signed a stipulated cease and desist order under which he agreed to not do what he was charged with and to stop using the title "D.D.S." in the State of Colorado unless he clearly discloses that he is not licensed to practice in Colorado. The full text of Judge Connick's 71-page report is posted on Casewatch.

Findings of Fact

4. For the past 22 years, Respondent [Huggins] has limited his practice of dentistry to the diagnosis and treatment of patients he believes are mercury toxic due to the placement in their mouths of dental amalgam filings which contain mercury.

6. Respondent originally used amalgams in his dental practice. As early as 1973, Respondent became aware of anecdotal cases of medical improvements reported on removal of amalgams. Respondent states that he then began to observe similar phenomena in his own practice. It was at this time that Respondent adopted as his life's prime objective "exposure of mercury's destructive potential.

8. Respondent is the only dentist in the United States who trains other dentists how to treat patients with alleged mercury toxicity due to dental amalgams.

11. Over time the Huggins Center has had a staff of approximately 50 employees, including approximately three dentists, dental assistants, nurses (including a psychiatric nurse who assists patient who experience emotional upsets when their amalgams are removed), nutritional counselors, massage and movement therapists; a video producer, accountants, other business employees, and, for a while, a physician.

13. The Huggins Center accepts for treatment patients with just about any symptoms and . . . . encourages prospective patients suffering from almost any illness to seek treatment from the Center and offers them assurances that their health will improve.

16. Many of the patients who seek treatment at the Huggins Center are very ill and are desperately seeking help.

17. The Huggins Center accepts the patient's medical diagnosis (e.g., multiple sclerosis), makes a diagnosis of mercury toxicity, and then treats the purported mercury toxicity and medical disease.

22. On several occasions, Respondent has told patients that he had MS and was cured, even though in fact Respondent has never suffered from this disease.

23. Respondent has designed two separate "detoxification programs," offered at the Huggins Center. The first is a comprehensive in-office program for those with serious problems. This program generally lasts two weeks, although it takes three weeks for ALS and leukemia patients. The Huggins Center has approximately 250 patients a year in this in-office program. The cost of this program is about $6,000 plus charges for the actual dentistry. The second is an "assist" program" to patients outside Colorado, those with more moderate problems, and those interested in prevention. The assist program costs approximately $380 plus charges for serum compatibility testing and dental work.

38. Respondent admits that he cannot prove the link between mercury from dental amalgam and disease but believes that he is entitled to rely on his clinical experience which suggests such a link.

39. When asked to state the scientific basis for his theories on mercury toxicity from amalgams, root canal extractions, and cavitations, Respondent was very vague. While he was able to identify a handful of studies on which he relied, he generally referred to thousands of publications in his library which supported his position, although he had not supplied them to the Board in response to their requests and could not identify them. He also sought to portray questions seeking to identify these studies as unreasonable by, for example, indicating that his goal is to treat patients and not to "rattle off" citations in the literature. In addition, he indicated his philosophy that the absence of proof in not the proof of absence.

40. It is highly probably that had additional studies lent credence to Respondent's practices, he would have supplied them or at least been able to identify them in substantially greater detail, particularly in light of the fact that he knew the scientific bases of his practices were being questioned and his dental license was at stake.

72. Respondent testified that there are thousands of articles which establish that amalgam causes multiple sclerosis but was unable to give citations "off the top of his head."

87c. Respondent consistently represents that the Huggins Center has an 85% success rate, measured by an improvement in patient symptoms and chemistries. Respondent believes that his treatments are effective and that it is only the patient's unwillingness to continue adequate nutritional and other follow-up or the patients falling into the unlucky 15% which prevents success. Because there is no scientific basis for the diagnosis or treatment performed at the Huggins Center, this statement is misleading, deceptive, and false.

89. As its standard protocol, the Huggins Center extracts all teeth which . . . have had root canals performed on them, even when they are asymptomatic.

110. As part of his diagnosis of mercury toxicity, Respondent uses a mercury toxicity questionnaire involving approximately 500 very general questions which are not connected to mercury toxicity and which have no diagnostic value. For example, the questionnaire inquires whether a patient has ever experienced emotional irritability, but this is not a sign or symptom of mercury toxicity.

169a. Respondent represents that both massage and sauna help remove toxins from the body. Respondent represents that sweating from a sauna aids a normal excretory mechanism of the body and removes mercury. . . . Respondent admits that there is no scientific evidence supporting his contentions in relation to sauna but relies on his experience. There is no scientific evidence that mercury is eliminated from the body through perspiration.

172. In his practice, Respondent has identified and named a phenomenon which he describes as "retention toxicity." Pursuant to this theory, a person excreting low levels of mercury in his urine is retaining mercury in the body and is severely ill.Retention toxicity thus refers to persons who are mercury toxic because of their inability to excrete mercury and indicates chronic illness.

173. Respondent bases his retention toxicity theory on his observations of patients who had few health problems until they received amalgam fillings and when those were removed, excreted more mercury and their symp_toms improved.

174. There is no valid scientific basis for Respondent's theory of retention toxicity. The excretion of a small amount of mercury does not indicate mercury toxicity. Rather, low excretion indicates a low body burden ofmercury. A patient with normal kidney function excretes more mercury the more he has on board. The fact that urine mercury levels indeed increase after· amalgam removal is due to the removal process, which causes transient exposure from the grinding and displacement of the mercury, and not to an enhanced ability to excrete mercury.

175. By diagnosing patients with retention toxicity and providing treatment based on that theory, when there is no clinical justification for it, Respondent has failed to meet generally accepted standards of dental practice.

Conclusions of Law

1. The Board has jurisdiction over Respondent, his license, and the subject matter of this proceeding.

2. In relation to Count I, since July 1, 1986, in his book, publications, and videotapes, Respondent has engaged in advertising which is misleading, deceptive, and false in violation of Section 12-35-118(1)(k), C.R.S. (effective July 1,1986). . . .

3. In relation to Count II and specifically patients D.A., G.B., M.B., A.G., H.G., H.S., G.S., and Dr. T.F., Respondent has engaged in acts or omissions which fail to meet generally accepted standards of dental practice or which constitute grossly negligent dental practice, in violation of Section 12-35-118(1)a), C.R.S. (1995). . . .

4. In relation to Count III, since July 1, 1986, Respondent has practiced dentistry as a partner, agent or employee of or in joint venture with any person who does not hold a license to practice dentistry in Colorado or has practiced dentistry as an employee of or in joint venture with a partnership, association, or corporation other than as provided in Section 12-35-112, C.R.S., a violation of Section 12-35-118(1)(9), C.R.S. (effective July 1, 1986).

5. In relation to Count IV and specifically patients D.A., G.B., M.B., A.G., H.G., H.S., G.S., and Dr. T.F., Respondent has abandoned his patients by failing to provide reasonably necessary referrals to licensed physicians for consultation or treatment in violation of generally accepted standards of dental practice and in violation of Section 12-35-118(1)(v), C.R.S. (1995). . . .

6. In relation to Count V and specifically patients D.A., G.B., A.G., H.G., H.S., G.S. and Dr. T.F., Respondent has engaged in willful and repeated ordering and performance, without clinical justification, of demonstrably unnecessary laboratory tests or studies; the administration, without clinical justification, of treatment which is demonstrably unnecessary; the failure to perform referrals when failure to do so is not consistent with the standard of care for dentistry; and the ordering or performing without clinical justification of services and treatment which is contrary to recognized standards of the practice of dentistry as interpreted by the Board, in violation of Section 12-35-118(1)(x), C.R.S. (effective July 1, 1989). In relation to M.B., the only treatment rendered after the effective date of Section 12-35118(1)(x) was the prescription of supplements, which constitutes a violation of this section. . . .

7. In relation to Count VI, the above violations of the Dental Practice Law also constitute violations of Section 12-35-118(1)(h), C.R.S. (effective July 1, 1986).

Initial Decision

Once violations of Section 12-35-118(1), C.R.S., have been established, the Administrative Law Judge must determine what disciplinary sanction, if any, is appropriate. Such sanctions may be suspension of a license for a period of not more than one year; revocation of a license; or reprimand, censure or probation. Section 12-35-118(1), C.R.S. In this matter, the Board's counsel seeks revocation of the Respondent's license. Respondent asserts that no discipline is appropriate.

In his practice of dentistry at the Huggins Center over the years, Respondent has engaged in a pattern and practice of violating the Dental Practice Act. He first engages in deceptive advertising to entice patients to seek dental treatment for their 9 serious medical problems when in fact there is no known link between their teeth and general health or between the treatment offered and any improvement in their health.

The efficacy of this deceptive yet seductive advertising is shown by the thousands of telephone calls coming into the Huggins Center every month.

Respondent instills fear in the public that the mercury in their amalgams is poisoning their bodies. His emotionally-charged publications, laced with scientific references and terminology, are designed to convince the public not only that amalgams are the undiscovered cause of everything from MS to Alzheimer's disease, but that there is a simple cure which offers them an amazing and tantalizing 85% success rate. The Huggins Center holds the key to their improved health.

Respondent offers hope not just to a few. His espoused treatment offers to remedy a host of conditions, including tremors, seizures, MS, ALS, Alzheimer's disease, emotional disturbances, depression, anxiety, unprovoked suicidal thoughts, lupus, scleroderma, rheumatoid arthritis, unexplained heart pains, high and low blood pressure, tachycardia, irregular heartbeat, osteoarthritis, chronic fatigue, "brainfog," digestive problems, and Crohn's disease. The sheer breadth and number of these diseases is staggering. They include a number of life-threatening and debilitating conditions for which medical science offers only symptomatic treatment. When faced with these serious diseases, it is no wonder that patients are willing to grasp at any hope of improvement and turn to Respondent for the miraculous improvements he promises. The debilitating nature of the diseases for which Respondent offers treatment and the desperate straits of a number of his patients, combined with the lack of any scientific basis for the treatments he offers, make Respondent's conduct particularly egregious. Respondent has taken advantage of the hope of his patients for an easy fix to their medical problems and has used this to develop a lucrative business for himself.

The diagnostic techniques and treatments offered by Respondent at the Huggins Center are scientifically unsupported, without clinical justification, and outside the practice of dentistry. The standard protocols which Respondent has developed thus provide care which does not meet generally accepted standards of dental practice and, in many cases, is grossly negligent. Instead of referring patients to physicians who could actually treat their underlying medical diseases and who could make a diagnosis of the mercury toxicity which Respondent suspects, Respondent simply ignores the limits of his qualifications and licensure and proceeds to treat these patients. He subjects patients to a wide array of tests and treatments. which have no clinical justification.

In relation to the eight patients at issue here, Respondent used his standard protocols. While all these patients suffered financially due to Respondent's intervention, a number of them also suffered physically or emotionally. Respondent's encouraging D.A. to believe in her son's wish that she sell her wheelchair is so out of proportion to any benefit which could be anticipated that it is cruel. The Huggins Center treatment caused actual harm to A.G.'s mouth and gums, as well as her appearance, under circumstances when her prognosis was very poor. Far from affording her the hoped-for improvement of her liver cancer, the Huggins Center treatment actually diminished her well-being during the last months of her life. In relation to H.S., the Huggins Center diagnosis of her being very sick, coupled with the disclaimer of any liability if she proceeded without full treatment, caused her to transfer to the significantly more expensive in-office program and to experience emotional upset, which was aggravated when she was later told she had cancer.

Along the way, Respondent has clearly become convinced that his treatments are effective and that it is only the patients unwilling to continue adequate nutritional and other follow-up or those unlucky 15% who will not benefit from his treatment. He is perfectly capable of ignoring the large body of scientific evidence which suggests that his theories in every arena are not credible; citing scientific literature selectively; exaggerating findings or studies which appear to support to his work; referring to the thousands of publications which support him yet being unable to produce those; and asserting that his clinical experience, as biased and unscientific as that may be, is itself the only support he needs. Respondent essentially says "trust me" to the dental profession and the public but provides no reasonable basis upon which he should be trusted.

Given his steadfast and longstanding commitment to his theories in the face of substantial reasoned evidence to the contrary, it is evident that nothing will stop Respondent from practicing the treatments he has developed short of revocation of his license to practice dentistry. Such disciplinary action is also justified by the multiple violations of the Dental Practice Act proven in this matter, especially those involving grossly negligent care.

Accordingly, it is the Initial Decision of the Administrative Law Judge that Respondent's license to practice dentistry in the State of Colorado is revoked.

This article was revised on November 23, 2012.