Houston prosecutors accuse a woman of performing neuromodulator injections without a medical license. Police say she injected three women in March 2025 with counterfeit Botox that caused physical injuries, including one complaint of a punctured nerve.

Although the woman displayed what appeared to be nursing certificates in her office and claimed to be “nurse certified” on her website, she has no such license and was not supervised by a medical professional. The woman is charged with practicing medicine without a license causing physical harm.

Legal review for compliant med spas

Texas med spa regulations require that neuromodulators (and other medical spa services that are considered the practice of medicine) be provided under the supervision of a physician who is trained and qualified to perform medical aesthetic procedures. These injections can only be performed by a physician or a person acting under the supervision of a physician, while following proper protocols and working under a valid delegation agreement. 

What patients should expect in a safe med spa

Botulinum toxin type A injections (Botox, Dysport, Xeomin, Jeuveau, Daxxify, Letybo) are prescription medicines, so they need to be prescribed and overseen by licensed medical practitioners.

Before you get an injection, a prescribing provider will meet with you to perform an initial consultation (also called a "good faith exam"). In Texas, this may be a physician (MD/DO) or a nurse practitioner (NP/APRN) or physician assistant (PA) acting under the delegation of a supervising physician. It’s a 10-step process that involves taking your medical history, performing a physical examination and recommending appropriate treatment. This prescribed treatment plan instructs your aesthetic injector where and how much to inject to give you the best outcomes.

To learn more about what to expect in a safe med spa, read what aesthetic trainers have to say about red flags and best practices in these articles:

Injectables Safety: What Patients Should Know About Dermal Filler and Neurotoxin

What to Look for in a Safe Med Spa Visit

A Patient's Guide to Med Spas

Review your state med spa laws

AmSpa arms Texas med spas with comprehensive legal resources to operate responsibly and in compliance with state boards and regulations. Keep up with the latest guidance by reviewing your state legal summary and taking advantage of your annual consult with the leading national health care law firm, ByrdAdatto. Join the Texas State Chapter to become part of an engaged community championing safe practices in medical aesthetics.