Three nurse practitioners are seeking to appeal a California judge’s ruling, which upheld state law restricting nonphysicians with doctorate degrees from calling themselves “doctor,” according to federal appeals court documents.
After pushback from California officials, the NPs have until April 1 to further state their position.
The case began in June 2023, when three nurse practitioners with Doctor of Nursing Practice degrees filed a lawsuit against California Attorney General Rob Bonta, president of the state’s medical board, Kristina Lawson, and executive officer of the state’s board of registered nursing, Loretta Melby, MSN, RN. The lawsuit centered on a California law that allows only physicians and surgeons to use the word “doctor” or the prefix “Dr.”
On Sept. 19, 2025, a federal judge ruled nonphysicians cannot call themselves “doctor,” saying its use in clinical settings is “inherently misleading” commercial speech and not protected by the First Amendment.
The three NPs — Jacqueline Palmer, DNP, RN, Heather Lewis, DNP, RN, and Rodolfo Jaravata Hanson, DNP, RN — filed an appeal to the 9th Circuit Court of Appeals Sept. 30.
Here are two more updates on the case:
1. On Feb. 9, the defendants — Mr. Bonta, Ms. Lawson and Ms. Melby — urged the appeals court to side with the district court’s September ruling. The California Medical Association and American Medical Association also submitted an amicus brief Feb. 17.
The medical associations argue against expanding the “doctor” title to NPs with doctorate degrees, claiming this case is “not only about speech rights,” but “could unsettle decades of well-developed laws, practices and policies governing how medical care is delivered,” according to the amicus brief.
“The NPs want to call themselves doctors because it would serve their professional and commercial interests, but they do not, and indeed could not, assume the legal duties and responsibilities of state-licensed physicians,” the brief said.
2. The federal appeals court granted the plaintiffs an extended time to file brief. Their deadline for an optional reply brief is April 1.
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