Case library · California · 2024–2026
What actually gets a California therapist disciplined
In short
What actually gets a California therapist disciplined?
Thirty real cases, the exact code section each was charged under, and what each one cost
103 decisions read, 30 written upEvery LMFT and AMFT disciplinary decision the Board of Behavioral Sciences published between 2024 and 2026, read in full. Thirty of them are written up here — what happened, which subdivision of §4982 it was charged under, how it resolved, and what it cost. No names. Every case number is given so you can pull the signed decision yourself.
The shape of itThe thirty casesWhat it costsInsurance that answers for it
There are no names on this site, and that is deliberate
Every name is public record. The Board publishes them in its own quarterly newsletter and the Department of Consumer Affairs hosts the signed decisions. This site does not republish them, for an editorial reason rather than a legal one: a page that names people becomes a page people arrive at by searching a name, and at that point it has stopped teaching anything.
Nothing has been softened. Conduct, statute, outcome and dollar figure are exactly as each decision states them. Cities, employers and client initials are removed. Every case below carries its case number and effective date.
To verify any case here: open the Board's quarterly newsletter archive at bbs.ca.gov/resources/general.html, find the “Formal Disciplinary Actions” section of the issue covering the effective date, and match the case number. Each licensee name in those PDFs is a live link to the signed Decision and Order.
The shape of it
Discipline does not usually start with a client.
This is the finding that surprises most therapists, and it is not an interpretation — it is the Board's own reporting. In FY 2023–24 more complaints came from government agencies than from members of the public, and the largest single driver of MFT discipline in California is the Department of Justice conviction and arrest feed under Penal Code §11105.2. Sixty-two of the 103 decisions read for this library cite §4982(a), a substantially related conviction. Most of those are a DUI. None of them began with someone complaining about therapy.
| Figure | What it is | Context |
|---|---|---|
| 2,127 | complaints received by BBS in FY 2023-24 | across all license types — up from 1,803 three years earlier |
| 1,006 | of them came from government agencies | more than the 952 that came from members of the public |
| 47 | accusations filed that year | out of 2,127 complaints |
| 415 | days, on average, from complaint to formal discipline | against a 540-day target |
| 7 | malpractice settlement reports in four years | averaging $360,000 paid on behalf of the licensee |
| 51% | of cases settle | 219 settled against 210 that went to hearing over four years |
Source: the Board's 2025 Sunset Review Report, section 4.
Which subdivision of §4982, and how often
Counted from the text of the 103 decisions. A single case can cite several.
| Subd. | What it prohibits | Cases | Note |
|---|---|---|---|
| (a) | Conviction of a substantially related crime | 62 | Overwhelmingly the most cited ground. Mostly DUI. |
| (c) | Substance use dangerous to self or others | 32 | Almost always paired with (a). |
| (i) | Intentionally or recklessly causing emotional harm | 13 | The standard companion count in every boundary case. |
| (e) | Violating the chapter or a Board regulation | 12 | The hook that pulls all of 16 CCR into §4982. |
| (d) | Gross negligence or incompetence | 9 | Every dual-relationship case. |
| (k) | Sexual misconduct with a client or former client | 6 | |
| (j) | A dishonest, corrupt or fraudulent act | 5 | |
| (m) | Failure to maintain confidentiality | 4 | |
| (b), (p), (u), (w), (y) | Fraud in licensure, advertising, experience hours, child abuse reporting, records access | 1 | One case each — and each one is in this library. |
The complete subdivision list, (a) through (ab), is in the Board's Statutes and Regulations at article 2.
And what gets cited, short of an accusation
A citation and fine is not formal discipline, and it is far more common. These are the five grounds the Board reports citing most often, in its own order:
- Failure to complete specific continuing education coursework requirements
- Failure to maintain patient confidentiality
- Providing services for which licensure is required — unlicensed practice, or practicing on an expired license
- Misrepresentation as to the type or status of a license or registration held
- Misrepresentation as to the completion of continuing education requirements
Two of those five are about continuing education and one is about confidentiality. None of them is clinical.
The library
Thirty cases, grouped by what went wrong.
Each one opens to a full write-up: the facts as the decision states them, every statute charged with a link to the code section, the disposition, the cost recovery, what the rule actually requires, and where a liability policy does and does not reach.
Sexual boundaries · 6
Six cases. One went to a full hearing; the rest settled. The penalty floor here is the highest in the guidelines, and for sexual contact as defined in §729 the revocation cannot be stayed by anyone — not the administrative law judge, not the Board.
The clinical director who slept with an inpatient, then asked him for $5 millionSeven years of probation and $15,883 — the largest cost recovery in three years of California MFT discipline.LMFTDecember 19, 2024seven yrs probation$15,883“We could date if we ended therapy”Said out loud in session, to a client the accusation described as vulnerable to exploitation. License surrendered, $12,515.LMFTDecember 19, 2024Surrendered$12,515Coffee three days after the final sessionAn intern who never told his supervisor, “for fear of being fired.” Four years of probation.LMFTApril 4, 2024four yrs probation$4,254Eight years, one client, and four sessions on MDMATrainee to intern to licensed private practice, with the same client throughout. License surrendered.LMFTOctober 24, 2024Surrendered$7,826Denied it to her employer, admitted it two days laterOne of the few cases in this dataset proved at a full hearing by clear and convincing evidence. Registration revoked.AMFTSeptember 25, 2025RevokedThree years of small steps, no single eventThe most carefully documented escalation in the whole dataset. License surrendered, $8,039.LMFTDecember 4, 2025Surrendered$8,039Boundary drift with no sexual contact · 5
Five cases where nobody touched anybody. Texting, emails, dinners, a sleepover, a shared joint. These are the cases most worth reading, because in every one of them the therapist could have described what they were doing out loud and it would still have sounded reasonable to them.
“Hope” and “Faith”Two clients from a residential eating-disorder program, code names in the text messages, and two overnight stays. Five years of probation.AMFTMarch 6, 2025five yrs probationThree years of probation for an email correspondenceNo touching. No meetings. No sex. “Dear One,” “My Candle Light,” “Have faith in my guidance.” $7,644.LMFTJuly 24, 2025three yrs probation$7,644Smoked with a client, drove her home impaired, offered her Xanax“I did put us in danger driving.” Registration surrendered, $5,000.AMFTJuly 24, 2025Surrendered$5,000“Do you know where a gal could get some E?”Texted to a client after 54 documented sessions. Registration surrendered, $8,107.AMFTOctober 24, 2024Surrendered$8,107One afternoon: drank at lunch, came back, saw clientsThat is the entire factual record. Four years of probation, $5,190.LMFTJuly 24, 2025four yrs probation$5,190Records, confidentiality and the file · 3
Three cases about paper. A letter written for the wrong person, a records request ignored for six months, an address never updated. Confidentiality is the second most common ground for a citation in California, ahead of everything clinical.
The letter written for the ex-spouseConfidentiality, altered records and a missed child abuse report, in one case. License surrendered, $12,242.LMFTSeptember 25, 2025Surrendered$12,242Revoked outright for how the practice was runSeven causes for discipline. No sexual misconduct, no substance use, no clinical error alleged at all.LMFTJuly 24, 2025RevokedThe address of recordA separate, chargeable violation for not telling the Board where you are.LMFTApril 4, 2024SurrenderedMoney, billing and honesty · 3
Three cases. One involves no clients at all — the conviction came from a bookkeeping job — and it still cost the registration.
The supervisor had died, and the hours still needed signingThe §4982(u) case — experience hours, a forged signature, and an email chain that documented all of it.AMFTDecember 4, 2025three yrs probation23 sessions billed in a single day17.25 hours of psychotherapy. More than 24 sessions a day on 75 different dates. Seven felony counts.LMFTSeptember 25, 2025Revoked62 checks written at a bookkeeping job, and a revoked registrationNothing to do with therapy, no client involved, and the registration went anyway.AMFTFebruary 12, 2026RevokedDiscipline that arrives from somewhere else · 4
Four cases under §4982.25. If any other board, in any state, disciplines any healing-arts license you hold, that fact alone is unprofessional conduct in California. A certified copy of the other board's decision is conclusive evidence — there is nothing to relitigate.
The psychology board acted, and the MFT license followed§4982.25(a): another board's discipline is itself unprofessional conduct here.LMFTSeptember 25, 2025two yrs probation$3,000The 30 days that made it worseAnother board's discipline, plus a separate count for not reporting it. License surrendered.LMFTSeptember 25, 2025Surrendered$1,859Disciplined in Arizona, surrendered in CaliforniaA license you keep current in another state is a live exposure here.LMFTMarch 6, 2025Surrendered$2,345The floor of the sanction ladderA public reproval — the mildest formal outcome available, and the only one in three years.LMFTMarch 6, 2025Public reprovalFitness-to-practice examinations · 1
One page, three cases, one lesson: an order to be examined is not a request, and ignoring it is its own independent ground for revocation with no §4982 charge attached.
The order to be examined is not a requestThree cases, three revocations, and in one of them no §4982 charge at all.LMFTApril 4, 2024SurrenderedConvictions, including the ones with nothing to do with therapy · 5
Five cases from the largest category in the data by a wide margin. Sixty-two of the 103 decisions cite §4982(a). Most of those are a DUI. None of them started with a client complaint.
Two DUIs, five years of probation: the most common case in CaliforniaSixty-two of 103 decisions cite §4982(a). This is what the typical one looks like.LMFTMay 15, 2025five yrs probation$2,201A reckless driving conviction, charged six timesThree causes on the MFT registration, then the same three repeated on the counselor registration.AMFTFebruary 12, 2026five yrs probation$2,578Licensed since the 1980s, surrendered after one DUIOffense in April, conviction in June, license gone by February.LMFTFebruary 12, 2026Surrendered$2,090Charged for conduct that was never prosecutedTwo convictions, and then two more causes for incidents that produced no conviction at all.LMFTJanuary 18, 2024three yrs probation$5,083The whole arc: conviction, probation, then surrender seven months laterThe clearest illustration in the dataset of what failing probation costs.LMFTJune 26, 2025, then February 12, 2026SurrenderedWhat happens after discipline · 3
Three cases about the part nobody plans for. Probation runs three to seven years, you pay for the monitoring, you tell your clients and your employer, and the coursework you are ordered to take does not count toward your continuing education.
Four ways to violate probation, and one of them is not payingIncluding failure to pay the cost recovery from the original order.LMFTDecember 19, 2024Revoked$4,530The Board asked for $10,778. The judge ordered $4,000.How §125.3 cost recovery actually gets decided.LMFTJune 26, 2025Probation$4,000Seven years on probation and countingThree extension cases, and what an extension actually means.LMFTApril 4, 2024Probation extended$3,432What it costs
Cost recovery is the number therapists most underestimate.
Business and Professions Code §125.3 lets an administrative law judge order a licensee found in violation to pay the reasonable costs of investigating and enforcing the case, including the Attorney General's charges. It is separate from your own lawyer, separate from any fine, and no insurance policy sold to therapists pays it. The judge can reduce it. The judge cannot increase it.
| Ordered | Typical fact pattern |
|---|---|
| $882 – $2,500 | A single DUI, settled early |
| $2,500 – $5,500 | Multiple convictions, or a settled boundary case |
| $5,000 – $8,200 | A contested boundary or dual-relationship case |
| $7,600 – $12,500 | Sexual misconduct, or a multi-client business-practice case |
| $15,883 | The highest in three years — the residential-facility sexual misconduct case |
None of that includes your own defense counsel, the psychological or psychiatric evaluation the order requires you to pay for, the practice-supervision arrangement, the remedial coursework that cannot be counted toward your continuing education, or the income lost during a suspension.
The fifteen probation conditions
These appear in essentially every probation order the Board writes. Two of them are the ones therapists never think about until they are living under them.
| Condition | What it means in practice |
|---|---|
| Obey All Laws | Any new offense is a violation. |
| File Quarterly Reports | The single most commonly missed condition. |
| Comply With the Probation Program | — |
| Interviews With the Board | — |
| Failure to Practice / Tolling | Stop practicing and the clock stops, but the obligations do not. |
| Notify the Board of Any Change of Employment or Residence | — |
| Supervision of Unlicensed Persons | — |
| Notification to Clients | You must tell your clients you are on probation. |
| Notification to Employer | And your employer. |
| Violation of Probation | — |
| Maintain a Valid License | — |
| Surrender in Lieu of Revocation | The condition the Board invokes when probation fails, without starting a new case. |
| Coursework Does Not Count Toward CE | You pay for the ordered coursework, and then you pay for your continuing education separately. |
| Reimbursement of Probation Program Costs | Roughly $1,200 a year. |
| Cost Recovery | Separate from everything above. |
The penalty attached to each violation is set out in the Board's Uniform Standards and Disciplinary Guidelines, which is the document the Board uses to price every settlement it offers.
Where insurance actually reaches
Read the thirty cases and the pattern is hard to miss: almost none of them is a malpractice claim. Nobody sued. The Board saw seven malpractice settlement reports in four years, against 2,127 complaints in a single year. The $1,000,000 limit that every therapist shops on is not the number that matters here — the board-defense sublimit is, and depending on the program it is $5,000, $25,000 or $35,000.
- Board defense is the coverage you are statistically most likely to use, and it is the smallest number on the policy.
- Sexual misconduct is defense only on every program a California therapist can buy. There is no indemnity, and some policies condition even the defense on the allegation being unfounded.
- Cost recovery is not a defense cost. No sublimit pays it, on any policy, ever.
- Probation is entirely uninsured — monitoring fees of roughly $1,200 a year, ordered evaluations, supervised practice, and coursework that does not count toward your CE.
- Associates are usually not named insureds on an employer's policy, and the employer has no reason to carry board-defense cover for someone else's registration.
How this library was built. The Board does not publish a browsable list of its decisions. It publishes a quarterly newsletter, and in the “Formal Disciplinary Actions” section of each issue every licensee name is a live hyperlink to the signed Decision and Order, Stipulated Settlement or Accusation hosted by the Department of Consumer Affairs. Eight issues cover July 2023 through March 2026 with no gap. Reading all eight yields 286 disciplinary entries across every BBS license type; 152 are LMFT or AMFT; 104 took effect in 2024, 2025 or 2026. 103 of those 104 source documents were retrieved and read in full — one entry had no hyperlink in the newsletter. Checked August 2026.
Most of these are stipulated settlements. In a stipulated settlement the licensee does not admit the allegations; they agree the Board could establish a prima facie case, and they accept the discipline. Where a case went to a full hearing instead, the case page says so.
This is not legal advice. We are not lawyers. If you are facing a Board matter, the single most useful thing on this page is the observation that a licensing attorney and a criminal defense attorney are different jobs, and that you probably want both. The Board's brochure on therapist sexual misconduct, which §728 requires therapists to provide in certain circumstances, is here.
