Appeals Court Refuses to Rehear Medical Education Speech Suit

December 29, 2025, 8:12 PM UTC

A California continuing medical education instructor won’t get a new hearing on her challenge to the state’s requirement that each course include a unit on implicit bias in health care, a federal appeals court said Monday.

The three judges who originally rejected Azadeh Khatibi’s claim that the requirement violated her First Amendment rights unanimously denied a panel rehearing, and the full court—with three judges dissenting—denied a petition for a rehearing en banc.

The case arose prior to President Donald Trump’s campaign to do away with diversity, equity, and inclusion initiatives in all walks of life.

Khatibi, an ophthalmologist who teaches ...

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