A U.S. federal court has upheld California’s prohibition on nurses with doctoral degrees from referring to themselves as “Dr” in clinical settings, ruling that using the title by nonphysicians is “inherently misleading” in healthcare.
On September 19, the U.S. District Court for the Central District of California rejected a lawsuit brought by three nurses holding Doctor of Nursing Practice (DNP) degrees. The plaintiffs had challenged the state's ban, arguing it violated their First Amendment rights by restricting the use of the title “Dr” in their professional roles.
Judge Jesus G. Bernal, in his opinion, characterized the use of “Dr” by DNPs as commercial speech that could mislead patients into believing they were interacting with a licensed physician. He concluded that the law serves a substantial government interest, protecting patients from confusion and that the restrictions are appropriately tailored.
The court referenced survey evidence cited by the American Medical Association, which found that 39% of patients believed a DNP is a physician.
Under California’s Business and Professions Code Section 2052, using the title “doctor” without holding a valid physician certificate is a misdemeanor and may attract sanctions.
The plaintiffs argued the statute was overly broad, that the speech was truthful given their doctorate credentials, and that prohibiting it altogether was more restrictive than necessary.
The California Medical Association (CMA) and the American Medical Association (AMA) submitted an amicus brief in support of the law. The CMA stated the decision upholds a “well-established prohibition against nonphysicians using the title ‘Dr’ in healthcare settings,” with the stated goal of protecting patient clarity.
This ruling reaffirms that healthcare title regulations may limit professional speech when patient misunderstanding is plausible. Some legal observers believe the decision might influence other jurisdictions considering similar restrictions, especially where scope-of-practice tensions exist.
Critics from nursing advocacy circles argue the lawsuit’s failure may stifle recognition of advanced nursing credentials. One attorney remarked that denying DNPs use of “Dr” despite their rigorous training and degree may seem unfair, though acknowledged the court’s concern over patient confusion.
If other states adopt laws parallel to California’s, the ruling may serve as precedent in legal disputes over professional titles in healthcare.
In its 2025 decision, the federal court in California upheld a state law barring nurses with doctoral degrees from using “Dr” in clinical settings, deeming such use potentially misleading to patients. The ruling underscores the tension between professional identity and patient protection, and it may influence policy and litigation around healthcare credentials in other U.S. states
(Rh/Eth/TL)