Federal Complaint Filed in Texas Challenges Federation of State Medical Boards Guidance on Physician Speech

Dr. Mary Kelly Sutton, a physician and plaintiff in federal case 3:25‑cv‑02936‑K, filed in the U.S. District Court for the Northern District of Texas.
Action filed by four physicians and nonprofit PPRM seeks judicial review of licensing policies affecting medical expression.
The complaint alleges that coordinated enforcement of FSMB‑issued guidance limited physicians’ ability to express independent clinical judgment and constituted an overreach of administrative authority affecting professional speech. The filing asserts that these practices began before the COVID‑19 pandemic and expanded as medical boards adopted uniform disciplinary standards based on FSMB policy statements.
The plaintiffs include Dr. Mary Kelly Sutton, Dr. Mary Talley Bowden, Dr. Mark Brody, and Dr. John Humiston. The nonprofit plaintiff, Physicians and Patients Reclaiming Medicine (PPRM), is described in the filing as a 501(c)(3) educational and advocacy organization.
According to its official website and organizational materials, PPRM’s core mission is to restore integrity to medical practice and establish patient‑physician autonomy as a fundamental right.
The complaint seeks declaratory and injunctive relief and requests judicial review of whether policies derived from FSMB guidance impermissibly restrict constitutionally protected professional expression under the First Amendment.
The Federation of State Medical Boards has previously stated that its recommendations are intended to promote patient safety and maintain public trust in medical licensure.
“Every patient deserves a doctor who can speak freely. Every doctor deserves the right to think,” said Dr. Mary Kelly Sutton, a plaintiff whose license was revoked for citing family history of adverse vaccine reaction as a valid reason for vaccine exemption.
Case Information
U.S. District Court for the Northern District of Texas
Case No. 3:25‑cv‑02936‑K
Filed October 29, 2025
Legal Counsel for Plaintiffs
Ilya I. Feoktistov, Esq.
292 Newbury St., #544
Boston, MA 02115
Media and Administrative Contact
K Lavelle
Physicians and Patients Reclaiming Medicine
contact@reclaimingmed.org
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