Posted February 10th, 2026 

You earned the doctorate.
You worked for the title.
But in California healthcare clinical settings, using “Doctor” could cost you thousands — and your license. 

That is not speculation. It is settled law — and now, settled federal precedent. 

A recent federal court ruling reaffirmed what California has enforced for decades: in clinical settings like hospitals, the title “doctor” is legally reserved for physicians. For everyone else, even those with earned doctorates, using the title can be deemed misleading — and punishable.

The Law Many Clinicians Overlook

California Business and Professions Code § 2054 strictly limits who may use the title “doctor” or the prefix “Dr.” in healthcare settings. The statute allows only licensed physicians and surgeons (MDs and DOs) to use the title when interacting with patients or the public in clinical contexts.
This law has existed in some form since at least 1937. Its purpose is not to diminish education or professional achievement. Its purpose is patient protection — ensuring patients clearly understand the licensure, authority, and scope of the professional treating them.

The restriction applies broadly, including:
⦁    Hospitals and clinics
⦁    In-person patient interactions
⦁    Professional websites and directories
⦁    Advertising and marketing materials
⦁    Social media used for clinical or professional representation

The Federal Case That Reaffirmed the Rule

In Palmer v. Bonta, three California nurse practitioners holding Doctor of Nursing Practice (DNP) degrees challenged § 2054, arguing that the law violated their First Amendment rights.

They claimed that because they had earned doctorates, they had a constitutional right to call themselves “doctor” in healthcare settings.
On September 19, 2025, U.S. District Judge Jesus G. Bernal rejected that argument.

The court held that:
⦁    The use of “Dr.” or “doctor” by non-physicians in clinical settings is commercial speech
⦁    That speech is “inherently misleading” to patients
⦁    Misleading commercial speech is not protected under the First Amendment
In other words: free speech does not protect professional titles that confuse patients.

Why the Court Agreed With California 

The court emphasized a key point regulators have long recognized:
patients reasonably associate the title “doctor” with physicians.
Even when a clinician holds a legitimate doctorate:
⦁    Patients may assume physician-level medical training
⦁    Patients may misunderstand clinical authority or decision-making power
⦁    Patients may not grasp scope-of-practice distinctions

California law exists to prevent that confusion before it causes harm.

This Rule Applies Beyond Nurse Practitioners
This decision is not limited to nurse practitioners.
Psychologists, social workers, and other clinicians with doctoral degrees are subject to the same restriction in healthcare settings.
That includes professionals with:
⦁    PhD or PsyD degrees
⦁    DSW or PhD degrees in social work
⦁    Other non-medical doctorates

In hospitals, clinics, and patient-care environments, these professionals must be identified by their licensed role, not the title “Doctor.”

Compliant examples include:
⦁    Clinical Psychologist
⦁    Licensed Psychologist
⦁    Licensed Clinical Social Worker (LCSW)

This is about licensure clarity, not academic prestige. 

Enforcement Is Real — and Costly

The risks are not hypothetical.

In the Palmer case:
⦁    One nurse practitioner was fined $20,000
⦁    Another was fined $2,500
⦁    Violations stemmed from using the title “doctor” on professional websites and social media

Penalties for improper title use may include:
⦁    Significant fines
⦁    License discipline
⦁    Regulatory scrutiny
⦁    Reputational harm

Importantly, intent is not required. If patient confusion is likely, enforcement can follow.

California Is Not an Outlier

California is not alone. States such as Indiana, Minnesota, and Tennessee have similar truth-in-advertising or title-protection laws.
The shared principle is simple:
Patients have the right to know who is treating them — clearly and accurately.

What Healthcare Organizations Should Review Now

This ruling is a compliance reminder for individual clinicians and healthcare organizations alike.

Organizations should be reviewing:
⦁    Staff badges and name plates
⦁    Website bios and provider directories
⦁    Marketing and advertising materials
⦁    Telehealth introductions
⦁    Social media profiles linked to clinical services
Policies should clearly define:
⦁    Approved professional titles
⦁    Required licensure disclosures
⦁    Responsibility for monitoring compliance
Title misuse is often an organizational compliance failure, not just an individual one. 

The Bottom Line

California law — now reaffirmed by federal court — is clear:
in patient-care settings, the title “Doctor” belongs to physicians.

DLH Enterprises | Healthcare Compliance & Patient-Rights Consulting
Healthcare compliance extends beyond HIPAA and documentation. It includes how professionals represent themselves to patients and the public. DLH Enterprises provides compliance reviews, policy development, and training on licensure disclosures, advertising rules, and risk reduction under California healthcare law. 

References: 
Case: Palmer et al. v. Bonta et al., 2025
California Medical Association 9/24/2025
Becker’s Hospital Review, 9/29/ 2025