Nurse Practitioners Sue California Over the Right to Use 'Doctor'

Should a nurse practitioner with a Doctor of Nursing Practice (DNP) call themselves a doctor? In California, doing it in a clinical setting can get you fined. Three doctoral-prepared NPs sued the state over that restriction, and the case has tested where the line sits between accurately describing your credentials and misleading patients.

Why Three NPs Sued the State

Jacqueline Palmer, Heather Lewis, and Rodolfo Jaravata Hanson, all DNP-prepared nurse practitioners, sued the California attorney general and the leaders of the Medical Board of California and the Board of Registered Nursing for the right to use "doctor" in their titles. The 2023 suit, filed with the Pacific Legal Foundation, challenged California Business and Professions Code section 2054 as an unconstitutional limit on speech.

The push came after Sarah Erny, a California DNP, was fined nearly $20,000 for referring to herself as a doctor on social media and professional websites. Palmer said she had introduced herself as a doctor while always explaining her nursing education and making clear she was not a physician, but Erny's penalty pushed her to act.

"My patients all have said that they know that I worked hard for it," Palmer said. "They know that I'm a nurse practitioner. There was no misconception."

What the Law Says in California and Beyond

California law reserves "doctor," "physician," the prefix "Dr.," and the initials "M.D." for graduates of medical school who are licensed to practice medicine. Anyone else who uses those terms on a sign, business card, letterhead, or advertisement is guilty of a misdemeanor.

Other states have moved the same direction. Georgia enacted a law barring non-physician clinicians with doctoral degrees, including advanced practice nurses and physician assistants, from identifying as doctors, and requiring practitioners to list their actual licenses on all advertising. Indiana passed a similar law in 2022 focused on the misuse of medical specialty titles by non-physician clinicians.

How the Case Turned Out

On September 19, 2025, a federal judge in the Central District of California upheld the restriction. In Palmer v. Bonta, U.S. District Judge Jesus G. Bernal treated the use of the titles as commercial speech and rejected the First Amendment challenge, writing that the law "directly advances California's substantial interest in protecting consumers from misleading advertising by medical professionals." The three nurse practitioners are appealing to the Ninth Circuit.

Should DNP-Prepared NPs Be Called 'Doctors'?

Doctoral degrees exist across many fields, so the argument is rarely about the degree itself. It is about what to say in front of patients.

Jacqueline Miller, DNP, FNP-C, an endocrinology nurse practitioner, argues DNP-prepared NPs have earned the title in clinical settings. "Nurse practitioners that earn a doctorate in nursing practice deserve to use the title 'doctor' in a clinical setting in spite of the controversial views perceived by their colleagues," she said. She adds one condition: patients have to clearly understand they are seeing an advanced practice nurse with a doctorate, not a physician.

Gary Gaddis, MD, PhD, a clinical professor of emergency medicine at Washington University in St. Louis, disagrees on the clinical question. "In an academic setting, they could appropriately ask to be called 'doctor,'" he wrote in Missouri Medicine. "But to call themselves 'doctor' in a clinical setting misleads the patient and perpetrates a fraud which defies their patient's trust." He points to a training gap, arguing NP programs offer less depth in pre-clinical sciences like anatomy and physiology and clinical sciences like pharmacology than medical or osteopathic schools.

The debate is not settled, but the shared ground is clear: patients should never be misled about who is providing their care.