Case library / Money, billing and honesty
62 checks written at a bookkeeping job, and a revoked registration
In short
Registration revoked
RevokedNothing to do with therapy, no client involved, and the registration went anyway.
No client, no session, no connection to therapy at all — and the registration went anyway.
What happened
She was employed as an accounts payable clerk at a plumbing company — a job with no connection to her registration or to any client.
She wrote 62 checks to herself, totalling $183,200.
She was convicted on 33 felony counts of grand theft by embezzlement and one count of money laundering, with an aggravated white-collar crime enhancement. The sentence was 365 days in county jail stayed, two years of supervised probation, and $195,600 in restitution.
What it was charged as
Conviction of a substantially related crime.
A dishonest, corrupt or fraudulent act substantially related to the duties of a licensee.
The outcome
Registration revoked.
No cost recovery stated in the orderWhat the rule actually says
“Substantially related” is defined by 16 CCR §1812 as conduct that to a substantial degree evidences present or potential unfitness, judged on three factors: the nature and gravity of the offense, the number of years since it happened, and the nature and duties of a marriage and family therapist. Dishonesty involving money and a position of trust clears that bar without ever touching a client.
Discussion
Analysis, not part of the decision
She was an accounts payable clerk at a plumbing company. Sixty-two checks to herself, $183,200, 33 felony counts of grand theft by embezzlement plus money laundering and an aggravated white-collar enhancement. Not one element of it touches a client or a therapy room.
The bridge is the phrase “substantially related.” Title 16 §1812 defines it as conduct that to a substantial degree evidences present or potential unfitness, judged on three factors: the nature and gravity of the offense, the number of years since it happened, and the nature and duties of a marriage and family therapist. Sustained dishonesty involving money and a position of trust clears that bar comfortably, because the duties of the profession include handling other people's vulnerability honestly.
This is worth internalising because it is the answer to the question therapists actually ask, which is whether something in their private life is the Board's business. The test is not location. It is what the conduct evidences.
Where insurance reaches, and where it does not
Entirely outside professional liability coverage — it is not a professional service, there is no claimant, and criminal acts are excluded. The board proceeding that follows is a board-defense claim, and it is the reason to check whether your sublimit is per proceeding or per year.
What would have changed it
- The teaching point is simply that §4982(a) and (j) reach your whole life. Bookkeeping, a second job, a shoplifting charge, a bar fight — the test is the §1812 relationship test, not whether it happened at work.
- The Board learns about it automatically. Convictions and arrests arrive at BBS through the Department of Justice notification feed under Penal Code §11105.2, which is the single largest source of BBS discipline. There is no version of this where nobody finds out.
Questions
For a law and ethics seminar, or for yourself
- Apply the three §1812 factors to a hypothetical shoplifting conviction from eleven years ago. Reach a conclusion and defend it.
- Is there conduct serious enough to be criminal that is not substantially related to the practice of marriage and family therapy? Give an example and justify it.
- What obligation did she have to the Board, and when did it start?
Source. This write-up is drawn from the signed public decision in the case number above. Names, cities and employers have been removed — why. To pull the original, open the Board's quarterly newsletter archive, find the issue covering February 12, 2026, and match the case number in the Formal Disciplinary Actions section. Not legal advice.
