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Christian Doctors Win After ADF Sues Over Assisted Suicide in California

A Christian physician and the Christian Medical & Dental Associations sued the state of California.
Alliance Defending Freedom
An elderly woman is seen in bed with her hands folded over her lap

In a disturbing trend, proponents of physician-assisted suicide (PAS) are increasing their efforts to legalize the practice across the country. Unfortunately, 10 states (plus the District of Columbia) now allow some form of physician-assisted suicide, and hundreds of patients have died by PAS in recent years.

California is one of those states. And—as if California’s dark embrace of death as an aspect of “health care” wasn’t bad enough—state leaders took things to a new low in 2021. In October of that year, Gov. Gavin Newsom signed SB 380 into law, reducing the waiting period for physician-assisted suicide from 15 days to just 48 hours.

But this law didn't just affect patients and their families. California required health-care professionals, regardless of their conscience or religious beliefs, to actively facilitate the process of ending a patient’s life.

The state required health-care professionals to assist patients’ access, upon their request, to an assisted suicide. Thus, doctors who hold to basic medical-ethics principles (e.g., “do no harm”) faced a terrible choice: either participate in the physician-assisted suicide process or potentially lose their practice and face civil or criminal penalties.

That’s why Alliance Defending Freedom filed suit on behalf of Dr. Leslee Cochrane and the Christian Medical & Dental Associations to protect the rights of their members and stand against California’s morbid desire to end life prematurely.

Let’s look at the specifics of this case.

Who are the Christian Medical & Dental Associations and Dr. Leslee Cochrane?

The Christian Medical & Dental Associations (CMDA) consists of the Christian Medical Association and the Christian Dental Association. It is a national organization of over 13,000 conscientious Christian health-care professionals whose personal religious convictions and professional ethics oppose practices like physician-assisted suicide. CMDA provides “resources, networking opportunities, education and a public voice for Christian healthcare professionals and students.”

“By being the ‘hands of Jesus’ to needy people, CMDA seeks to fulfill His Great Commandment (Matthew 22:39; 25:36) and His Great Commission (Matthew 28:19).”

Dr. Leslee Cochrane is a CMDA member and full-time hospice physician in California who is board-certified in family medicine with a certificate of additional qualification in hospice and palliative medicine.

CMDA and its members like Dr. Cochrane seek to live out their Christian beliefs in their practice of health care, including their belief in the sanctity of human life. It would violate their consciences to participate in assisted suicide in any way. But California law forced these health-care professionals to actively facilitate the PAS process.

CMDA members believe deeply that suffering patients need understanding and sound medical treatment, not encouragement to kill themselves. Their rights of conscience and religious freedom must be protected because the state has no authority to order them to act contrary to those sincere convictions.

That is why ADF represented both CMDA and Dr. Cochrane against the state of California.

Christian Medical & Dental Associations v. Bonta

In October 2021, Newsom signed SB 380 into law, weakening the already-permissive rules regulating the state’s physician-assisted suicide law. The original law, passed in 2015, required a 15-day waiting period after a patient’s request for assisted suicide, giving patients an opportunity to reconsider their choice, discuss with family, and get further input from medical professionals. That timeline was sharply reduced by the new law and now requires just 48 hours between requests.

Lawmakers claimed to have safeguards in place to protect the rights of doctors and patients. But the law demanded that even if a physician like Dr. Cochrane obeyed his conscience and declined to participate in a patient’s suicide, he must still participate in the process allowing the patient to obtain life-ending drugs from another physician.

In doing so, objecting physicians would be forced by California’s law to take required steps, like documenting a patient’s suicide request, that move the patient closer to death. Even the California State Legislature’s own analysis concluded that this compels health-care professionals to “affirmatively facilitate” the physician-assisted suicide of their patients.

Many doctors rightly see these requirements as facilitating the patient’s death and so cannot participate in the process. But if these health-care professionals had continued to stand on their deeply held beliefs and focus on helping and healing instead of killing, California's law could have subjected them to civil or criminal penalties and even the loss of their license. So, in February 2022, ADF filed a complaint, and then filed a motion for preliminary injunction in March.

Thankfully, in September 2022, a federal court granted our motion for preliminary injunction, saying that the California law violates the First Amendment rights of medical professionals by requiring them to participate in physician-assisted suicide against their religious convictions and professional ethics.


In May 2023, in a victory for the rights of medical professionals, California agreed in a settlement to no longer force doctors to violate their religious beliefs by participating in physician-assisted suicide. State officials vowed not to enforce “any criminal or civil punishment, including professional discipline or licensing sanction,” against California physicians who decline to participate in PAS.

In addition, California agreed to pay $300,0000 toward the attorneys’ fees for Dr. Cochrane and the other CMDA doctors who brought the lawsuit. The settlement ensures that California’s government will not force health-care professionals to violate medical ethics or their religious convictions to practice medicine.

Case timeline

  • October 2021: California passed SB 380, which forced physicians to participate in the process of assisted suicide, even when a doctor has conscientious objections.
  • February 2022: On behalf of CMDA and its members like Dr. Leslee Cochrane, ADF filed suit against the state of California to prevent the government from forcing health-care professionals to violate their conscience.
  • March 2022: ADF filed a motion for preliminary injunction to halt enforcement of California’s law while the lawsuit proceeded.
  • September 2022: A federal court granted ADF’s motion.
  • May 2023: California agreed to a settlement in which it vowed to no longer force doctors to participate in physician-assisted suicide. It also paid $300,000 toward attorneys' fees for the doctors who brought the lawsuit.

The bottom line

No government has the authority to force health-care professionals to choose between violating their beliefs and doing their job. Our laws must promote, encourage, and celebrate life—not endorse and foster death.

Learn more:

ADF client Dr. Leslee Cochrane explains how assisted suicide laws ignore medical ethics: