Riverside, CA; June 6, 2023: Today, a federal lawsuit was filed to challenge California’s unjust titling law, which prohibits the truthful use of the title “Dr.” by any professional who is not a licensed physician or surgeon.

Many nurse practitioners in California have earned a Doctorate of Nursing Practice (DNP), the highest nursing degree, and use the title “Dr.” — just like college professors and veterinarians. But DNPs risk fines and loss of their licenses and livelihoods if the state enforces Cal. Bus. & Prof. Code § 2054 against them.

“The state cannot appropriate a commonly used term and reserve it for a narrow range of practitioners,” said Pacific Legal Foundation attorney Donna Matias. “Many professionals commonly use the title “Dr.” — beyond physicians — and should be able to truthfully do so when describing their profession or accomplishments. Government censorship of professional titles is a thinly veiled attempt to protect well-connected industry insiders.”

Recently, Sarah Erny, a DNP, was fined over $20,000 and may lose her license for truthfully referring to herself as “Dr. Sarah” on her website. She moved to Washington state as a result of California’s punitive actions, which have struck fear in the DNP community. Although the state appears to be targeting only DNPs, anyone other than physicians and surgeons who uses the title “Dr.” is violating the law.

Most states allow professionals, including nurse practitioners, to use the title “Dr.” as long as they identify their particular field. This serves to protect patients while also protecting the practitioner’s First Amendment rights.

The case is Palmer v Bonta, filed in the U.S. District Court Central District of California, Eastern Division.


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About Pacific Legal Foundation

Pacific Legal Foundation is a national nonprofit law firm that defends Americans threatened by government overreach and abuse. Since our founding in 1973, we challenge the government when it violates individual liberty and constitutional rights. With active cases in 34 states plus Washington, D.C., PLF represents clients in state and federal courts, with 18 wins of 20 cases litigated at the U.S. Supreme Court.

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