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

Pacific Legal Foundation filed suit on behalf of Dr. Azadeh Khatibi, Dr. Marilyn Singleton, and Do No Harm challenging California’s mandatory implicit bias training for physicians.

In 2019, California lawmakers passed a chilling new mandate known as AB 241. In a purported effort to reduce healthcare disparities based on race, ethnicity, gender, or sexual orientation, the law requires that all continuing medical education (CME) courses involving direct patient care include implicit bias training—regardless of who teaches the course or what is taught.

UPDATE: Do No Harm appealed the lower court’s decision to the 9th Circuit on August 23, 2024. Oral arguments are expected in the Spring of 2025.