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 (California Business and Professions Code section 2054).
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.
Frequently Asked Questions
Can a nurse practitioner be called "doctor" in California? Not in a clinical or advertising setting. California Business and Professions Code section 2054 reserves "doctor," "physician," the prefix "Dr.," and "M.D." for licensed physicians, and using them otherwise is a misdemeanor, even for a nurse practitioner who holds a Doctor of Nursing Practice (DNP) degree.
What was Palmer v. Bonta about? Three DNP-prepared nurse practitioners, represented by the Pacific Legal Foundation, sued California in 2023, arguing the title restriction violated their First Amendment right to accurately describe their credentials.
How did the case turn out? On September 19, 2025, a federal judge in the Central District of California upheld the restriction, treating the titles as commercial speech and finding the law advances the state's interest in preventing misleading advertising. The plaintiffs appealed to the Ninth Circuit.
Does a DNP make someone a doctor? A DNP is a doctoral degree, so the holder has earned a doctorate, much like a PhD. The dispute is not about the degree itself but about whether using "doctor" in front of patients could lead them to believe they are seeing a physician.
Do other states restrict the title too? Yes. Georgia and Indiana have passed laws limiting how non-physician clinicians with doctoral degrees, including advanced practice nurses and physician assistants, identify themselves, and requiring practitioners to list their actual license on advertising.
What is the core disagreement? Supporters say DNP-prepared NPs earn the title and can use it as long as patients clearly understand they are advanced practice nurses, not physicians. Opponents argue using "doctor" in a clinical setting risks misleading patients about training and scope. Both sides agree patients must never be confused about who is treating them.