"The Wall Street Journal" notes specifically in its stylebook that "Lawyers, despite their J.D. degrees, aren't called "doctor", although the title is used (if preferred and if appropriate in context) for "individuals who hold Ph.D.s and other doctoral degrees" and for "those who are generally called doctor in their professions in the U.S." Many other newspapers reserve the title for physicians or do not use titles at all. In 2011, "Mother Jones" published an article claiming that Michele Bachmann was misrepresenting her qualifications by using the "bogus" title Dr. based on her J.D. They later amended the article to note that the use of the title by lawyers "is a (begrudgingly) accepted practice in some states and not in others", although they maintained that it was rarely used as it "suggests that you're a medical doctor or a Ph.D.—and therefore conveys a false level of expertise".