Court Rules Nurses with Doctorates Cannot Use “Doctor” Title with Patients
In a legal decision rendered September 19, 2025, a federal court in California upheld a state law that prohibits nurses who hold doctorate degrees (e.g. DNPs) from referring to themselves as “Dr” in clinical contexts with patients. The court found that such usage constitutes “inherently misleading” commercial speech and is not protected by the First Amendment.
Quick Insight: Even though many doctors, PhDs, and professionals with doctoral credentials use the “Dr” title in various settings, this ruling draws a line in health care settings where patient confusion is seen as a risk.
1. Background & Legal Challenge
• Three California-based nurses holding Doctor of Nursing Practice (DNP) degrees brought suit in June 2023, challenging the law as an unconstitutional restriction on free speech.
• Some plaintiffs had previously used “Dr” on lab coats, nameplates, social media profiles, or in clinical documents, often clarifying that they were nurses.
• The plaintiffs argued that using “Dr” was truthful, not misleading, and that banning that speech goes beyond what is necessary to protect patients.
2. Court’s Rationale & Ruling
• Judge Jesus G. Bernal ruled that the use of “Dr” in the clinical context is a form of commercial speech (promoting one’s professional services) which the state may regulate if it is misleading.
• The court determined that patients might reasonably believe that someone calling themselves “Dr” is a licensed physician, even if qualified as a nurse.
• The ruling noted evidence that 39% of surveyed patients believe that a DNP is a physician.
• Under California law, claiming the “Dr” title without a valid physician credential in healthcare or promotional settings can lead to misdemeanor charges.
3. Reactions & Broader Implications
• The California Medical Association and the American Medical Association supported the decision, citing patient clarity and professional transparency.
• Plaintiffs responded that governments should not silence truthful speech, especially when disclaimers or disclosures can alleviate confusion.
• Critics have pointed out an inconsistency: many doctorate holders (like PhD or EdD) use “Dr” freely in academic, legal, or public roles, while nurse practitioners are restricted in clinical settings.
• Legal commentators warn that this decision may be cited in other states or prompt similar laws elsewhere, especially as DNPs and advanced nurse roles grow.
4. What to Watch Going Forward
• Whether this ruling is appealed and/or affirmed at higher courts.
• Efforts by nursing associations or states to reform licensing rules or nomenclature laws.
• How nurses with doctorates present their credentials (e.g. “Jane Doe, DNP, Nurse Practitioner”) in line with legal limitations.
• Patient perception and trust factors—will clarity improve, or will restrictions create tension in professional identity?
