When any healthcare provider introduces themselves as “doctor,” most patients may naturally assume they’re speaking to a physician. But what happens when the person using that title isn’t an MD, but a nurse with a doctoral degree?
In evolving healthcare environments where nurse practitioners (NPs), pharmacists, physical therapists, and other professionals are earning doctorates, the question of who gets to be called “doctor” may be called into question. For many patients, the title carries a certain weight.
But for professionals who aren’t physicians yet hold doctoral degrees, using the title “Dr.” may become controversial, especially in clinical settings. This tension recently came to a head in California, where a legal ruling reaffirmed the state’s stance that only physicians may use the title “doctor” when interacting with patients, even if another clinician holds a doctorate.
On September 19, 2025, the U.S. District Court for the Central District of California issued a decision: California’s law prohibiting nonphysicians from using the title “Dr” in clinical settings is constitutional, and nurses with doctorates may not present themselves to patients simply as “doctor.”
Background of the case
Three California nurses holding Doctor of Nursing Practice (DNP) degrees sued the state in 2023, challenging a section of the California Business & Professions Code that makes it a misdemeanor for nonphysicians to use the title “Dr.” in advertisements or clinical settings.
The plaintiffs had used “Dr.” on clinician jackets, on social media, in clinical documents, and in introductions with patients, even while disclosing they were a NP.
Their argument was that the statute violates their First Amendment free speech rights and that using “Dr.” isn’t misleading because they disclose their nursing role. The state responded that the restriction is a permissible regulation of “commercial speech,” i.e., speech tied to the business of providing healthcare services, and that the prohibition is necessary to protect patients from confusion.
The court upheld the state's position.
The court’s rationale
The court ruled that when nurses with doctorates use the title “Dr.” in clinical settings, it qualifies as commercial speech, meaning it’s tied to the provision of professional services and can be more regulated.
A major factor in the court’s decision was the risk of patient confusion. The court cited a survey conducted by the American Medical Association showing that nearly 40% of respondents believed a Doctor of Nursing Practice (DNP) was a physician.
Given that many patients associate the title “doctor” with medical doctors, the court determined that restricting its use in patient care settings helps avoid potentially misleading impressions.
“It is critical in healthcare settings where there is a provider-patient relationship that patients have a clear understanding of role clarity,” said Felicia Sadler, MJ, BSN, RN, CPHQ, LSSBB, Vice President of Quality and Clinical Workforce Development at Relias. “However, I can appreciate that APN's want recognition for doctoral degree status in the provision of care.”
In academic settings, clear distinctions are often made between the roles and educational pathways of advanced practice nurses (APNs) and those who hold a DNP degree. According to Sadler, this setting is where these differences are most explicitly recognized and understood.
This distinction becomes especially important as nursing continues to evolve, and more nurses pursue terminal degrees. While the DNP represents the highest level of clinical nursing education, it doesn’t equate to a medical degree.
In academic and other interprofessional environments, role clarity is more readily acknowledged; however, in patient-facing roles, consistent communication and transparency about credentials can help maintain trust and minimize confusion.
What it means in nursing practice
When interacting with patients, nurses with doctorates, such as a DNP or PhD, may want to use caution about how they present their credentials. In California, they’re prohibited from introducing themselves as “Dr.” in clinical settings.
“Educating the public and local communities about the scope of practice, professional titles, and varying state regulations for APNs is essential for promoting both clarity and trust in healthcare,” said Sadler. “Even in states where APNs don’t function under the supervision of a licensed physician, it is a good practice to be transparent with patients as part of building a trusting relationship.”
Healthcare organizations across California must enforce this regulation by reviewing and updating all materials that identify staff. This includes signage, nameplates, lab coats, and business cards.
Clinics, hospitals, and group practices will need to align with the law and educate their teams on appropriate title usage to avoid misrepresentation and potential fines or other legal consequences.
Beyond clinical settings, educational institutions and nursing organizations should take steps to support compliance and provide guidance. Nursing schools may need to counsel doctoral graduates on how to use their titles appropriately. Professional associations might also engage in advocacy to protect the recognition of advanced nursing credentials while promoting clearer, fairer laws.
Final thoughts on nurses with doctorates and this case
This recent California ruling reinforces the need for clarity in how healthcare professionals present their credentials to patients. Nurses with doctorates have rightfully earned their title through rigorous academic and clinical work.
However, the court emphasized that in clinical settings, patient understanding must come first. Because of this, APNs in California must now clearly state their role when identifying themselves, ensuring patients understand the difference.
At the same time, the case highlights a broader challenge within modern healthcare: how to honor the achievements of non-physician professionals while maintaining transparency for patients.
