No. 25-1240October Term 2025Before Arguments
Azadeh Khatibi v. Kristina D. Lawson, President of the Medical Board of California
from the United States Court of Appeals for the Ninth Circuit.
Case status
- Current stage
- Before Arguments
- Latest event
- Accepted by the Court
- Decision timing
- No window until argument is scheduled.
- What it's about
from the United States Court of Appeals for the Ninth Circuit.
Question presented
Whether private instruction in courses required for state licensure constitutes government speech.
- Case path
United States Court of Appeals for the Ninth Circuit / Accepted by the Court
- Area
Supreme Court case awaiting argument
Timing
Expected by late June 2026, if argued this term
The Court granted review but has not yet scheduled oral argument. Once argued, the median case reaches a decision in 94 days. Nearly all cases are decided by the end of the term in which they are argued.
Briefing
What it's about
California requires doctors to complete 50 hours of continuing medical education every two years to keep their licenses. Petitioners say the state's rule requiring every course to address implicit bias forces private instructors to carry a state message, and they ask whether that teaching counts as government speech.
Argument
The case is pending at the petition stage, and no oral argument is scheduled. Petitioners argue California compelled private CME instructors to deliver a state-required message in violation of the First Amendment.
Impact
The case could affect doctors, medical educators, and groups that design accredited courses for license renewal. For example, even a highly technical course on retinal tumors may have to include state-required discussion of implicit bias.
What is at stake in Khatibi v. Lawson?
The case asks whether California can require private CME courses to include instruction on implicit bias. The challengers say that requirement forces speech.
Who could be affected by California's CME rule?
Doctors renewing licenses, medical teachers, and professional groups that create accredited courses could be affected. Even technical classes may need state-required content.
What happens next in Azadeh Khatibi v. Lawson?
The Supreme Court must decide whether to grant certiorari (agree to hear the case). No oral argument is scheduled, and no decision window is listed yet.
Related cases
Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Aug 4, 2026
- Method
- Methodology