Source Article – Nurses With Doctorates Cannot Tell Patients They’re Doctors, Court Rules

In a September 29, 2025, decision, a federal court held that DNPs in California may not present themselves as “doctor” in clinical settings, affirming a state law that regulates professional titles.

The court’s ruling rejected claims that the prohibition violated free speech rights, declaring that the use of “Dr” by nonphysicians in health care is “inherently misleading” commercial speech.  Pacific Legal Fund attorney Donna Matias, who represented the nurses, said “Instead of reining in the state’s power to censor professionals who accurately describe their credentials, the decision emboldens it.” “The First Amendment does not allow the government to silence truthful speech simply because some listeners may be confused — especially when disclosure can address any concerns short of a total ban.”

In his opinion, Judge Jesús G. Bernal emphasized that “the potential for confusion is significant when a healthcare provider uses the title ‘doctor’ without immediately identifying their discipline.”

Here is where some other states stand on this issue:

• Georgia – Passed the Health Care Practitioners’ Truth and Transparency Act: advanced practice nurses (including those with doctoral degrees) using “doctor” in a clinical context must explicitly state they are not medical doctors.
• Texas – Allows DNPs to use “doctor” as a title provided they also clearly indicate their authority or degree.
• New Hampshire – The NH Board of Nursing holds that DNPs (and PhDs in nursing) may use the prefix “Doctor” in all settings (clinical and otherwise), if the degree is from a nationally accredited institution.
• Maine – ME has a bill (HP0382, LD‑538) that would allow those with DNP degrees to use “Doctor” or “Dr.” as a prefix, provided the suffix “DNP” follows their name.
• Florida – Legislation has been proposed but not enacted.