While each state has its own legal definitions of sexual misconduct, for ethical purposes it is helpful to begin with a clinical measure.
Ethical Standards and Principles Regarding Sex in Therapeutic Relationships
While each state has its own legal definitions of sexual misconduct, for ethical purposes it is helpful to begin with a clinical measure. Brodsky, in 1985, (cited in Kertay & Reviere, 1993) proposed that the standard for defining erotic contact should be based on whether the behavior leads to sexual arousal for either the therapist or the patient. Thus, Brodsky would likely determine that purposeful sexual abuse has occurred when a therapist persists in any act that has been identified in the therapy as arousing to either party.
The American Psychological Association (APA, 1992, code 4.05) standards state that "psychologists do not engage in sexual intimacies with current patients or clients," and they "do not accept as therapy patients or clients persons with whom they have engaged in sexual intimacies" (p. 1605). They also say that psychologists do not have such intimacies with former patients or clients within two years of termination (code 4.07). The same code states that even if intimacies occur after two years the therapist must show that no exploitation has occurred.
The California Association of Marriage and Family Therapists (CAMFT, undated) standards state that "sexual intercourse, sexual contact or sexual intimacy with a patient or a patient's spouse or partner is unethical" (code 1.2). Further, the ethical codes for MFCCs in general say the same as does the California code, according to Rutter (1989). He also noted the standards for psychiatrists and social workers, which state that psychiatrists consider "sexual activity" with a patient to be unethical and that social workers should not engage in such activity under any circumstances. (p. 185).
With regard to pastoral counseling, Rutter noted:
All of the major religious organizations consider sexual relations between a pastor and parishioner to be highly unethical. Nevertheless, for a variety of reasons there are fewer clear statements to this effect from the clergy. For one, there are so many different religious groups, each with a tradition of complete autonomy, that it is difficult for them to join together in a consensual ethical statement. ... Many religious groups hold sexual activity between clergy and parishioners to be so overridingly wrong or sinful that they have never felt it necessary to say so. ... As one priest told me, "The church's position seems to be that since we can't do it at all, there is no point in telling us with whom we can't do it." (pp. 186-187).
Handling Patients' Claims of Sexual Misconduct
Smith and Gutheil (1993) have noted the need to carefully and patiently process claims directly with the accuser. They suggested that while it may seem urgent to act to prevent further damage to other clients, one's first responsibility is to process the claim with this client. The researchers further recommended that therapists accept the perception of the patient in the context of the therapy, but that they reserve judgment in the context of the professional and legal realms. They said that in these arenas, the therapist must consider the possibility of a false claim before acting to intervene, report or discipline. Smith and Gutheil argued for close supervision so that the therapist burdened with handling the claim can remain therapeutic with the client and keep advocacy out of the countertransference. Advocacy has its place in the reporting requirements, and may have a role in healing, but it is for the patient not the therapist-hero.
History and Progeny of the Sexual Taboo in Therapy
Having discussed the profession ethics regarding sexual contact between therapists/counselors and patients/clients (these terms will be used interchangeably), the remainder of this paper will explore what the scientific and theoretical literature has to say about crossing over from feelings and fantasies into actions and violations. (The reader will note that some researchers write in an apparently gender-biased or sexual-orientation biased fashion. It has seemed expedient to let their words stand, since most of them explain their choice of usage somewhere in their texts.)
"A taboo against sexual contact between healers and patients was well established as long ago as the writings of Hippocrates," stated Kertay and Reviere (1993). Rutter (1989) excerpted the Hippocratic Oath, part of which said: "In every house where I come I will enter only for the good of my patients, keeping myself far from all intentional ill-doing and all seduction, and especially from the pleasures of love with women or men, be they free or slaves" (unpaginated).
One of the earliest examples of the therapeutic desire to avoid erotic physical entanglements with patients came when Freud withdrew his support from Ferenczi partly because of the sexual interpretation that was associated with the latter's use of hugging and holding in individual work. Kertay and Reviere noted: "Those few early analysts who continued to use touch were quickly expelled from the ranks of orthodox psychoanalysis, as were Ferenczi and later Reich" (p. 33).
Other times, boundaries were not so clear, however. Said Gutheil and Gabbard (1993): "When Melanie Klein was analyzing Clifford Scott, she encouraged him to follow her to the Black Forest for her holiday. Each day during this vacation, Scott underwent analysis for a 2-hour session while reclining on Klein's bed in her hotel room." Further, they noted that D.W. Winnicott reportedly held Margaret Little's hands "clasped between his through many hours as she lay on the couch in a near-psychotic state." (p. 189). Gutheil and Gabbard also cited the fact that "psychiatrists traditionally performed their own physical examinations" (p. 195).
Objectivity and standardization obviously still needed attention. As Kertay and Reviere reported, the "difficulty in drawing appropriate distinctions between erotic and non-erotic contact" has been a primary worry. In part "ethical concerns regarding sexual contact between therapists and patients" led to a generalization that all touch was susceptible to misperception and therefore had no place in therapy. (pp. 33-34). The 1970s, however, saw a swing of the pendulum back again toward limited reacceptance of therapeutic "hugging, kissing, or affectionate touching" that was "non-erotic," with 34 percent of doctoral level therapists especially humanists engaging in the practice themselves (Holroyd & Brodsky, cited in Kertay Reviere, p. 34).
Meanwhile, the same research gleaned the following disturbing information:
5.5 percent of the male and 0.6 percent of the female licensed Ph.D. psychologists in [Holroyd & Brodsky's] sample admitted having sexual intercourse with their patients, and an additional 2.6 percent of the males and 0.3 percent of the females reported sexual intercourse with patients within three months of the termination of therapy. Of those who had intercourse with a patient, 80 percent repeated it. When all erotic contact was considered, 10.9 percent of the males and 1.9 percent of the females reported such contact with patients. (Kertay & Reviere, p. 36).
Since this research also showed that "the offending psychologists were often experiencing personal difficulties" (p. 36), one may hypothesize a correlation between therapist impairment and sexualization of the therapy. Additionally, Kertay and Reviere reported that Holroyd and Brodsky's follow-up work in 1980 showed that:
Therapists who differentially touched opposite-sexed patients but not same-sexed patients were at significantly higher risk for sexual contact with patients. In other words, it was the therapists' own attitudes toward the use of touch, whether erotic or non-erotic, which was a key factor contributing to sexual contact. (pp. 36-37).
Unfortunately, the APA standards at the time apparently did not explicitly specify that erotic contact was strictly forbidden, though such actions violated other stated principles i.e. those involving patients' welfare, therapists' responsibilities, and community standards. (Kertay & Brodsky, 1993). On the other hand, Kertay and Reviere noted 1982 work by O'Hearne stating that touch was still contraindicated when patients were "likely to misinterpret" it, and "when the therapist is aware of either hostile or sexual feelings toward the patient" (p. 35).
Pogrebin et al (1992) cited a 1987 study of more than 1400 psychiatrists. It found that "65 percent reported having treated a patient who admitted to sexual involvement with a previous therapist." They also noted 1986 research that still shows approximately 10 percent of therapists self-reporting at least one sexual liaison with a patient. (p. 229). Further 1987 research reported in Pogrebin et al suggests that this percentage likely understates the truth since some offenders either don't respond or don't make admissions.
Therapeutic Touch?
Given the historical findings, Kertay and Reviere noted some guidelines for the use of touch that would be consistent with therapeutic aims. First, it should not be used at all in the initial stages of treatment. Second, "the patient and therapist should discuss the use of touch, the relationship boundaries, and potential sexual feelings related to touch." Third, therapists should ask permission or let the client know each time they intend to attempt physical contact for any reason. The researchers reason that this "serves to keep the use of touch on a conscious level in the therapy." Fourth, the therapist must ensure that the patient feels in control of the use of touch and does not feel coerced in any way. If this can not be ensured, the issues of touch should be processed and its use reconsidered. (p. 38).
Finally, therapists "must be clear about their own motivations and must take full responsibility for their own and their patient's responses to touch." In this regard, Kertay and Reviere recommend that therapists who use touch as a "significant part" of their practice should have "ongoing supervision or peer consultation." (p. 39). These suggestions seem to constitute a minimum standard for preventing the abuse of touch in therapy and ensuring that "the laying on of hands" remains a healing gesture. This is especially important in light of other research examined below.
Boundaries, Perception and Power
Gutheil and Gabbard (1993) have noted that the "difference between a harmful and nonharmful boundary crossing may lie in whether it is discussed or discussable; clinical exploration of a violation often defuses its potential for harm" (p. 190). They and others (Rutter, 1989) have given examples of how to handle seductive clients, i.e. telling them to go back to their chair when they rise to touch the therapist, and then verbally exploring what just happened. They also noted the heightened sensitivity of patients who had been violated in childhood, making it less likely for them to see boundary crossing as benign. In addition to perceptual differences based on client history, other factors may have influence as well:
Kertay and Reviere (1993) found 1986 research, which stated that women were generally less likely to perceive "sexual intent" in men than vice versa, especially under such ambiguous circumstances as "casual touch" or "moderate interpersonal distance." They also cited a 1985 study indicating that both men and women saw therapists who use a "semi-embrace" as "more expert" but "less trustworthy." In compiling these findings, Kertay and Reviere further noted some 1988 work arguing that therapists should not touch clients because it "increases the power differential between therapist and patient and is therefore harmful" even when the contact is not considered sexual. (p. 37).
Given these findings, it is apparent that boundaries, perception and power all need to be taken into account when considering the ethical and clinical issues surrounding what constitutes sexual misconduct.
Kertay and Reviere stated that:
Sexual arousal and touch should never occur at the same time. Such a situation creates an unclear boundary at best and, at worst, can threaten and confuse the patient's sense of safety in the therapeutic relationship. If either therapist or patient is sexually aroused by touch, these feelings should be processed and the use of touch reconsidered. (p. 37).
On the other hand, Gutheil and Gabbard (1993) argued that it is problematic to assume all boundary crossing is harmful. While they noted that violations tend to slide toward sexual misconduct, those that don't may not necessarily represent bad technique. They drew a distinction between boundary crossing, violations and sexual misconduct. Gutheil and Gabbard posed three principles that governed these areas. The first principle acknowledges the "slippery slope" scenario alluded to above. The second one acknowledges the relativity of ideological perspectives on what constitutes a violation of standards about sexual misconduct. (p. 188). The final principle acknowledges that governing authorities tend to believe boundary crossing correlates with sexual misconduct. In this regard, the researcher pointed to evidence that courts found liability even where sexual contact was not an issue.
One of the points Gutheil and Gabbard tried to make in their 1993 work was that it is possible for some boundary crossing to be helpful, if it does not lead to sex. They maintained that "strict abstinence" from need gratification "is neither desirable nor possible" and that "total frustration of all the patient's wishes creates a powerful influence on the patient in its own right." They determined the appropriateness of gratification based on whether fulfillment would require a transgression or contribute to growth. The former case would be cause for abstinence and the latter would be desirable. (p. 191). This can be taken to mean that there are times when it may be appropriate to hug a patient, for example. Gutheil and Gabbard warn, however, that overgratification can end up feeling like a false promise to the patient who then expects to have all deprivations nullified.
An Ounce of Prevention
Thorn et al (1993) experimentally showed that a brochure about appropriate and inappropriate therapist behavior helped raise nonpsychotic patients' "intention to behave assertively" if sexual misconduct should occur, though for patients with personality disorders careful introduction and processing of the material was recommended. The researchers also envisioned that such a brochure might be useful in resolving a difficult transference. They stated: "The ability to show a client who is struggling with attraction or affection for his or her therapist the profession's stance on sexual involvement may give the therapist the needed leverage to help the client work through such issues" (p. 81). They further hope that their brochure might help a tempted therapist to analyze him- or herself out of acting in the moment, and that it would help clients recognize when a therapist is about to violate a boundary so they can disengage safely.
At minimum, the brochure was shown to have increased subjects' understanding of proper and improper therapist behavior, increased negative attitudes about particular acts such as therapists' disclosure about their own sex lives, and increased reported intent to speak against any therapist behavior that made subjects uncomfortable. This last effect made Thorn et al hopeful that where it was too late for prevention the brochure could help a victim to feel empowered to take action if desired, and that it would be useful for resolving residual feelings.
Gutheil and Gabbard (1993) recommended that "a patient in the midst of an intense erotic transference to the therapist might best be seen, when possible, during high-traffic times when other people ... are around" and noted that "a clinician interested in having a sexual relationship with a patient might well schedule that patient for the last hour of the day" (p. 191). These observations take into account the factor of opportunity, about which the researchers seemed to feel attorneys were particularly watchful.
The use of phone calls also can lead down the slippery slope, and Gutheil and Gabbard recommended taking great care about such calls especially with borderline patients, with whom it might be necessary to contract usage so that it is confined to emergencies. They noted as well that "a patient won a settlement in an allegation of sexual misconduct when the tape recording she had made of a phone call from her therapist revealed his intimate, seductive tone. The therapist's attorney urged the settlement for fear that the jury would hear the intimate tone as evidence of a sexual relationship" (p. 194).
It is even important for therapists to take care not to wear their clothing in a revealing manner that would be suggestive to the patient, Gutheil and Gabbard noted. (While a therapist may wish to carefully test a patient's sensitivity in such a way, if the result is positive it is time to move on to working through the response, not time to check for replicability.) If the patient comes in dressed seductively it is a technical error for therapists to explain their reactions, according to the researchers. Therapists are guided to calmly set limits with patients who behave seductively. (Sometimes an angry look will do, though.)
Gutheil and Gabbard warned against "creating a false sense of intimacy," and that in this regard it may even be appropriate to use clients' last names under certain conditions. With all patients, they recommended apologizing for boundary violations to prevent harm, and to ensure that all therapy sessions are conducted in a time and place that a jury would consider appropriate for clinical practice. They also noted that it can appear sexually inappropriate to let therapy bills slide. "In the minds of fact finders," Gutheil and Gabbard said, "this raises a question: 'The clinician seems curiously indifferent to making a living; could the patient be paying in some other currency?'" (p.192).
A good measure of prevention against sexual misconduct also lies in therapists attending to their own relationships and ensuring they have others to whom feelings can be disclosed. Too much or inappropriate self-disclosure with clients is a boundary violation that Gutheil and Gabbard said "may be used by the legal system to advance or support a claim of sexual misconduct. The reasoning is that the patient knows so much about the therapist's personal life that they must have been intimate" (p. 194). For this reason, too, it is important to document and justify interventions that could be construed as violations. While some modalities use asocial responses and others eschew them, these researchers suggested that when it comes to "social physical contact" a handshake is about all risk management can handle. If patients get out of line with physical contact, referral might be necessary, according to Gutheil and Gabbard.
The researchers noted that the Office of Public Affairs of the American Psychiatric Association has educational materials that are also useful for prevention. Additionally, there is an exploitation index put out by Epstein and Simon that forms a self-monitoring function. Further materials are referenced at the end of this paper, including a booklet put out by the State of California. The Rutter (1989) book also lists places to contact for help and information.
When Alliance Leads to Lust
The therapeutic alliance in a counseling relationship can precipitate a very intense form of intimacy. It is common for patients or clients to have sexual feelings for their therapists or counselors, and for therapists to fantasize about their charges. In many cases, one's own experience in therapy will verify these points. Moreover, said Rutter (1989), "any relationship that moves us deeply, even if it is clearly nonsexual, can stimulate sexual fantasy" (p. 63). "It is precisely because forbidden-zone relationships touch us so deeply that sexual fantasy pours into them," Rutter explained (p. 64). Regarding these relationships he added,
Their tremendous life-giving promise can be fulfilled, for both the man and the woman, even when it presents itself through the potentially dangerous medium of erotic fantasy. What matters in the forbidden zone is not keeping sexual thoughts away, but maintaining a boundary against sexual contact so that the unique potential of these relationships can be realized. Harvesting the nonsexual potential of the forbidden zone takesbesides resisting enactment of the sexual fantasytime, care, and enormous respect for the power inherent in these relationships. (p. 64).
What's Love Got to Do with it?
The intimacy and trust inherent in the therapeutic alliance can hold the hope of a valuable relationship that may feel like a connection based on love. Said Rutter:
It is clear that for both men and women the special conditions of forbidden-zone intimacy offers access to relationships that are felt to have immeasurable value. Under these circumstances the sudden meeting of a man and woman who have previously been strangers contains the potential to heal the wounds of the past and generate hope for a life filled with self-worth and meaningful connection to others. (p. 55).
Thorn, Shealy and Briggs (1993) recognized "normal feelings of attraction toward one's therapist." The gave subjects a brochure on "client-therapist intimacy" and found that it helped change attitudes about sexual misconduct. (p. 78). The point is that no matter how intimate one feels toward one's therapist, this love is not to be exploited under any circumstances.
Kertay and Reviere (1993) cited 1986 research by Pope et al, which found that while 93.5 percent of psychologists sampled said they never sexually acted out, only 13.2 percent (77 out of 585) said they were never attracted to clients sexually. The study also indicated that more males than females were likely to feel such attraction, and that younger rather than older therapists were more vulnerable to having these feelings.
Wilmer (reviewed in Rossi,1988) wrote what can be considered some clinical standards for Jungian therapy, albeit in humorous fashion. As noted by Richardson, the reviewer of Wilmer's book, the Jungian view of sexual misconduct acknowledges the shadow without condoning the practice.
RULE OF THUMB: Sex
No.
Some psychologists have said that there is nothing wrong with having sex with a patient. Would you believe it? You would? Oh! (p. 173).
Wilmer's book gives analysts the tips and techniques helpful for dealing with transference and countertransference, including falling in love and what to do when the patient confesses love for the therapist. Jungians can also recommend that their patients read a book more suited to their side of the therapy session. This one, by Hall (also reviewed in Rossi, 1988), tells patients what they can do when they've fallen in love with their analysts and offers other useful information for analysands. The point of these books is to handle the feelings that come up in therapy pragmatically, whether they are sexual feelings or otherwise. As one candidate at the C.G. Jung Institute of San Francisco admonished a seductive patient, "We talk about our feelings; we don't act on them."
Transference and Countertransference: "The alpha and omega of therapy"
The analytical response to love is to treat it as transference. Said Rutter:
Transference is a term used in psychotherapy for the powerful feelings that patients develop toward their therapists. Transference feelings are in some ways a reexperiencing of past emotional dynamics within the family, but in other ways they look to future possibilities for developing new and healthier emotional dynamics. For example, a patient trying to seduce a therapist may be repeating past injuries but is also most likely searching for a response that will discourage this repetition. The therapist draws these feelings out of clients because of the power he has either to reinjure his patients or to relate to them in a way that will free them from the wounds of the past. Many laws defining professional malpractice recognize the life-and-death power that the transference phenomenon grants the therapist and therefore place an extra responsibility on the therapist not to abuse the transference. (p. 50).
Countertransference is, in psychoanalytic literature (Arlow, cited in Corsini & Wedding, 1989), the "analyst's emotional response to the patient," and the "counterpart of the patient's transference onto the analyst." Here, the client's material stimulates the therapist's conflicts and unresolved fantasies, "causing him to misperceive, misinterpret, and misrespond to the analysand in terms of his own difficulties." (p. 48). In some cases of sexual misconduct, it is easy to see where countertransference could have contributed for example in instances of therapists acting on the idea that their clients needed physical intimacy to boost their self-esteem or lift them out of depression.
When the therapist believes his or her own feelings mirror those of the client, a process of projective identification may be underway. In this case, the therapist may easily lapse into discussing his or her own feelings with the client and even slip into using this mode as the principal form of treatment. However, the preferred response is for therapists to analyze the meaning of their feelings about the client without discussing the subject with the client. (Arlow, 1989). In fact, Thorn et al (1993) see therapists' excessive personal disclosures, especially those of a sexual nature, as part of sexual misconduct.
Arlow would likely tend to agree. He said:
Neurotic countertransference to the patient on the part of the analyst can constitute a real problem. ... If the problem persists, or if it can be demonstrated to be more pervasive than had been suspected before and to apply to other patients as well, it indicates a need for the analyst to undergo further psychoanalysis himself. When the analyst finds that he cannot control his counter transference [sic] responses, he discusses the issues honestly and frankly with the patient and arranges for transfer to another analyst. (pp. 48-49).
Even in therapeutic modalities in which countertransference is not necessarily treated as a neurosis, such as in analytical psychotherapy (Kaufmann, cited in Corsini & Wedding, 1989), it is still defined as a projection. Kaufmann said the countertransference should not be "avoided or minimized," but "fruitfully used" as a guide that points to the polar, or opposing, relationships symbolized in therapy, such as husband-wife. "The analyst can use his or her own reactions as a therapeutic tool," he wrote. "Those reactions provide information about what is going on in the analytic process. If, for instance, the analyst perceives in herself a spontaneous urge to bully her patient, she will know the master-slave configuration is operating." (p. 140).
Similarly, if the analyst feels drawn to the patient in a desire to mate, it may indicate that the husband-wife archetypes are constellated, and it is the symbolic, not concrete, aspects of this relationship that are to be explored. It is important to remember that countertransference is the "activation of unconscious wishes and fantasies" (emphasis added) of the therapist, and that as such they produce a "tendency to respond to patients as though they were significant others in the life or history or fantasy of the therapist" (Corsini & Wedding, 1989, p. 591). Thus, analytical psychotherapists (Jungians) are trained to deal with countertransference by discovering the kind of relationship it points to rather than acting it out.
This use of countertransference may come as a lesson Jung learned himself from experience. As Rutter notes:
Jung was one of the many powerful men who had problems with his own sexual shadow, and there is evidence that he had sexual relationships with two female patients. In view of these ethical violations, it is ironic that Jung's work provides a hopeful psychological framework for constructive reconciliation between oppositional viewpoints, whether based on politics, culture, or gender. (p. 52).
A Jungian View
Working through Anima/Animus Projections
What Jung came to theorize was that "the projection-making factor is the anima, or rather the unconscious as represented by the anima" (Campbell, 1971, p. 151). Jung said of this feminine image:
Whenever she appears, in dreams, visions, and fantasies, she takes on personified form, thus demonstrating that the factor she embodies possesses all the outstanding characteristics of a feminine being. She is not an invention of the conscious, but a spontaneous product of the unconscious. (Campbell, p. 151).
Thus, when a male Jungian fantasizes about a female patient, he is to consider her image as a symbol of his unconscious conception of the feminine, not as a representation of the patient's physical being. Similarly, when a female therapist fantasizes about a male patient, or when a female client holds erotic images of her male therapist, this is interpreted to reflect the woman's inner conception of the masculine her animus, which the man himself has come to symbolize. Said Jung:
The autonomy of the collective unconscious expresses itself in the figures of anima and animus. They personify those of its contents which, when withdrawn from projection, can be integrated into consciousness. To this extent, both figures represent functions which filter the contents of the collective unconscious through to the conscious mind. (Campbell, pp. 158-159).
Jungian theory postulates that because men carry an inner feminine aspect and women carry an inner masculine aspect, "men can learn to empathize with and respect women" by drawing on their own anima, and "women can understand and develop capacities they attribute to men" by drawing on their own animus (Rutter, p. 52). It is when the functions of the anima and animus archetypes are projected onto actual persons, and therefore remain unconscious, that such fatal attractions as forbidden sex can be acted out. Said Jung:
Both these archetypes, as practical experience shows, possess a fatality that can on occasion produce tragic results. They are quite literally the father and mother of all the disastrous entanglements of fate... . Together they form a divine pair... . Both of them are unconscious powers, "gods" in fact, as the ancient world quite rightly conceived them to be. To call them by this name is to give them that central position in the scale of psychological values which has always been theirs whether consciously acknowledged or not; for their power grows in proportion to the degree that they remain unconscious. Those who do not see them are in their hands... (Campbell, p. 160).
Sexual Integrity and the Gift of Coniunctio
Jungians see therapy as an alchemical process (Edinger, 1972). When integrity is maintained a spiritual alchemy occurs and transcendence and transformation take place through the "union of opposites" known as coniunctio (Edinger, 1972). For example, a "lesser coniunctio" is achieved when one reconciles the shadowy side of oneself, or when one integrates the anima or animus. The "greater coniunctio" occurs when one is in "full communion" with both the conscious and unconscious selves and a sense of wholeness is attained. (Edinger, p. 249).
In Jungian thought, wholeness can only be achieved when one captures one's "unconscious desirousness" and extracts its essence for the salvation of the psyche (Edinger, p. 258). While no empirical data can attest to this, personal experience verifies that when therapist and patient spiritually acknowledge, accept, explore and physically forego their ultimate forbidden desires they achieve a coniunctio that surpasses bodily sexual union. The experience is a mystery that can not be experimentally replicated at will. It is a gift that comes as if from grace.
References Cited
American Psychological Association. (1992). Ethical principles of psychologists and code of conduct. American Psychologist, 47(12), 1597-1611.
California Association of Marriage and Family Therapists. (undated). Ethical standards for Marriage and Family Therapists. San Diego, CA: CAMFT.
Campbell, J. (1971). The portable Jung New York, NY: Penguin.
Corsini, R., & Wedding, D. (Eds.). (1989). Current psychotherapies (4th ed.). Itasca, IL: F. E. Peacock.
Edinger, E. F. (1972). Ego and archetype New York, NY: Penguin.
Gutheil, T., & Gabbard, G. (1993). The concept of boundaries in clinical practice: Theoretical and risk-management dimensions. American Journal of Psychiatry, 150(2), 188-196).
Kertay, L, & Reviere, S. (1993). The use of touch in psychotherapy: Theoretical and ethical considerations. Psychotherapy, 30(1), 32-39.
Pogrebin, M., Poole, E., & Martinez, A. (1992). Accounts of professional misdeeds: The sexual exploitation of clients by psychotherapists. Deviant Behavior: An interdisciplinary journal, 13, 229-252.
Rossi, E. L. (Ed.) (1988). The Jungian experience: Analysis and individuation. [Review of book by Hall, J. A.]. Psychological Perspectives, 19(1), 169-171.
Rossi, E. L. (Ed.) (1988). Practical Jung: Nuts and bolts of Jungian psychotherapy. [Review of book by Wilmer, H. A.]. Psychological Perspectives, 19(1), 171-174.
Rutter, P. (1989). Sex in the forbidden zone: When men in power therapists, doctors, clergy, and others betray women's trust New York, NY: Fawcett Crest.
Smith, B., & Gutheil, T. (1993). A patient's false claim of therapist sexual misconduct. Hospital and Community Psychiatry, 44(8), 793-794.
Thorn, B., Shealy, R., & Briggs, S. (1993). Sexual misconduct in psychotherapy: Reactions to a consumer-oriented brochure. Professional Psychology: Research and Practice, 24(1), 75-82.
References Consulted
Conidaris, M., & Erikson, J. (1994). California laws for psychotherapists (p. 233). Gardena, CA: Harcourt Brace Legal and Professional.
Deaton, R., Illingworth, P., & Bursztajn, H. (1992). Unanswered questions about the criminalization of therapist-patient sex. American Journal of Psychotherapy, XLVI(4), 526-531.
Goisman, R., & Gutheil, T. (1992). Risk management in the practice of behavior therapy: Boundaries and behavior. American Journal of Psychotherapy, XLVI(4), 532-543.
Gutheil, T., & Gabbard, G. (1992). Obstacles to the dynamic understanding of therapist-patient sexual relations. American Journal of Psychotherapy, XLVI(4), 515-525.
Quinn, V. (undated booklet). Professional therapy never includes sex. Sacramento, CA: Department of Consumer Affairs.
Schultz-Ross, R., Goldman, M., & Gutheil, T. (1992). The dissolution of the dyad in psychiatry: Implications for the understanding of patient-therapist sexual misconduct. American Journal of Psychotherapy, XLVI(4), 506-514.
Strasburger, L., Jorgenson, L., & Sutherland, P. (1992). The prevention of psychotherapist sexual misconduct: Avoiding the slippery slope. American Journal of Psychotherapy, XLVI(4), 544-555.
© Darlene Viggiano, M.A. 1999.
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