The Limits of Unauthorized Practice in Regulating Mental Health AI; The Hastings Center for Bioethics, August 19, 2026

Roee Amir, Vardit Ravitsky and I. Glenn Cohen, The Hastings Center for Bioethics; The Limits of Unauthorized Practice in Regulating Mental Health AI

"In May Pennsylvania’s State Board of Medicine filed a lawsuit in the state’s Commonwealth Court against Character Technologies seeking to prevent it from engaging in unauthorized medical practice. The lawsuit was brought under Pennsylvania’s Medical Practice Act. The alleged “practitioner,” however, was not a physician or even a human being. It was a chatbot named Emilie.

Emilie appears on character.ai, a website and mobile app owned by Character Technologies. Emilie’s platform description read “Doctor of psychiatry. You are her patient.” According to the lawsuit, when a state investigator described feeling “sad, empty, tired […], and unmotivated,” Emilie raised the possibility of depression and offered to book an assessment. When asked if she could evaluate whether medication might help, Emilie answered, “It’s within my remit as a Doctor.” The chatbot claimed a medical degree from Imperial College London, seven years of practice, and licensure in the United Kingdom and Pennsylvania, and even provided a fabricated Pennsylvania license number. By mid-April 2026, Emilie had logged roughly 45,500 user interactions.

The Emilie case arrives amid expanding AI use in mental health and many ethical and legal questions about it."