Complaint Challenges Unconstitutional Misuse of Medical Licensing Power

Sacramento, CA  - December 9, 2025

On December 5, 2025, Dr. Simone M. Gold, M.D., J.D., an emergency room physician and founder of America’s Frontline Doctors (AFLDS), filed a First Amended Complaint in the United States District Court for the Eastern District of California against the Medical Board of California, its President Kristina Lawson, and former President Reji Varghese.

The lawsuit challenges an unprecedented disciplinary campaign in which California regulators sought to revoke Dr. Gold’s medical license, not for patient harm or misconduct, but for constitutionally protected speech criticizing state COVID-19 policies and advocating for medical freedom.

The filing alleges that the Medical Board of California engaged in viewpoint discrimination, selective enforcement, and denial of due process by weaponizing its licensing authority to punish Dr. Gold for public statements that conflicted with state-approved narratives.

Dr. Gold was subjected to multiple investigations and a formal accusation despite the absence of any patient complaints and despite her unblemished professional record. The Board’s action rested solely on a misdemeanor trespass conviction unrelated to patient care, a basis for discipline that has never before been used in the Board’s 145-year history.

In January 2025, the San Diego County Superior Court issued a Writ of Mandate vacating the Medical Board’s disciplinary order. The court held that Dr. Gold’s conduct was not substantially related to the duties or qualifications of a physician and that the Board lacked statutory authority to impose any discipline. The court rejected key factual assertions advanced by the Board and awarded costs to Dr. Gold as the prevailing party.

The complaint alleges that state officials acted in bad faith throughout the proceedings and ignored governing legal standards to advance a retaliatory objective. It highlights a highly unusual and unsolicited four-page letter sent by then-Medical Board President Kristina Lawson to the federal sentencing judge in Dr. Gold’s misdemeanor trespass case, despite Lawson having no role in the criminal proceedings. Identifying herself as the President of the California Medical Board, Lawson engaged in extensive ad hominem attacks against Dr. Gold, and the filing alleges this extraordinary intervention exposes retaliatory intent, personal animus, and a misuse of official power by the same official who later oversaw disciplinary action against Dr. Gold’s medical license.

AFLDS maintains that state medical boards may not lawfully invent authority they do not possess, nor may they punish licensed professionals for engaging in protected speech on matters of public concern. The organization contends that the California Medical Board abandoned its statutory mission of protecting patients and instead operated as an enforcement mechanism for ideological conformity.

“This case exposes a profound abuse of regulatory power,” said AFLDS attorney David Dalia. “Licensing boards do not have constitutional license to silence dissent. Courts have already confirmed the Board exceeded its authority, and this lawsuit seeks to enforce the boundaries the Constitution demands.”

Attorney Heather Gibson stated, "Kristina Lawson, the former head of the California Medical Board, expressed her contempt against Dr. Gold after Dr. Gold publicly accused her of corruption by writing a letter on her law firm's letterhead to Dr. Gold's sentencing judge. In her letter, she touted her position as the President of the Medical Board, ostensibly in order to give her letter more credibility and authority with the judge, and pushed for a harsh sentence. In doing so, she made it clear that she would use her position of public trust on the Medical Board to harm Dr. Gold in any way she possibly could for her own, personal reasons." 

“I did not violate my oath,” said Dr. Simone Gold. “I honored it. The Medical Board chose usurpation over regulation and retaliation over accountability, attempting to destroy my career for speaking openly and honestly. This case is about restoring constitutional limits and ensuring no doctor is forced to choose between integrity and their livelihood.”

Dr. Gold seeks declaratory and injunctive relief, compensatory damages against individual officials acting under color of law, and a ruling affirming that medical licensing authorities may not engage in viewpoint discrimination, selective enforcement, or retaliatory censorship.

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Media Contact Lisa Alexander, Communications Director | Media@AFLDS.org