Azadeh Khatibi et al. v. Randy Hawkins et al.

On August 1, 2023, Do No Harm, joined by Dr. Marilyn Singleton and Dr. Azadeh Khatibi, filed a federal lawsuit challenging a California law that requires private instruction in Continuing Medical Education (CME) courses to contain specified “implicit bias” training curriculum for physicians.

The case argues that California’s CME mandate violates the First Amendment rights of CME instructors by compelling their speech and placing unconstitutional restrictions on the free exercise of speech.

On April 28, 2026, following the Ninth Circuit’s affirmation of a California district court’s determination that CME courses constitute “government speech,” Do No Harm and Dr. Khatibi petitioned the Supreme Court of the United States (SCOTUS) to protect physicians’ free speech rights in the field of medicine.

Do No Harm has asked SCOTUS to stop California’s sweeping overreach, demonstrating that state’s CME mandate erases the constitutional boundary between government and private speech, threatens the speech rights of physicians and countless other professionals, and directly conflicts with well-established SCOTUS precedents protecting against compelled speech.