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Welcome to another episode of the CSA’s Podcast Vital Times
In September 2025, a landmark ruling by a California judge stated that nonphysicians could not use the term “Doctor” in a clinical setting. This was a ruling in response to a lawsuit filed by Three California-based nurse practitioners. They challenged California Business and Professions Code Section 2052, which makes it a misdemeanor for nonphysicians to use “Dr” in clinical settings or advertisements.
Judge Jesus G. Bernal wrote in the opinion that using the title “Dr.” by nonphysicians in clinical contexts is “inherently misleading” and amounts to regulated commercial speech. Because of that, it does not fall under free speech protections.
The court sided with the state, which argued that allowing nonphysicians to use “Dr.” could confuse patients about who is providing their care. Bernal cited an American Medical Association (AMA) survey showing: 39% of patients mistakenly believed that DNPs are physicians. He concluded that even when nurses disclose their credentials, the risk of confusion remains high in healthcare settings.
To help us understand the importance of both the law and the ruling - 3 amazing patient advocates ae joining the show today.
Dr. Rebekah Bernard is a family physician in Fort Myers, Florida. She's a founding member and past president of Physicians for Patient Protection, a grassroots advocacy group focused on ensuring physician-led care for all patients and truth and transparency among healthcare practitioners, and has authored two books on scope of practice.
Dr. Antonio Hernandez Conte -- Former Chair of CSA Legislative and Practice Affairs Division from 2019 to 2022. Hhen served as President from 2023-2024 and is now a Past-President. Dr. Hernandez Conte is also a Partner with the Southern California Permanente Medical Group and a Clinical Professor at the Kaiser Permanente Bernard J. Tyson School of Medicine.
Dr. Christina Menor is a board-certified anesthesiologist in private practice in Los Angeles. She specializes in ambulatory, pediatric and obstetric anesthesiology. Dr. Menor currently serves as the President for the California Society of Anesthesiologists. She coauthored an article describing California survey data about medical titles. She is a member of Physicians Protecting Patients and is an active advocate for physician led care and title transparency.