Case library / Discipline that arrives from somewhere else
Disciplined in Arizona, surrendered in California
In short
California license surrendered
$2,345A license you keep current in another state is a live exposure here.
A license you keep current in another state is a live exposure in California, with no California client required.
What happened
The Arizona Board of Behavioral Health Examiners disciplined the licensee's Arizona marriage and family therapy license.
BBS charged that discipline under §4982.25(a). The California license was surrendered.
What it was charged as
Discipline by another state on a healing-arts license.
The outcome
California license surrendered.
$2,345ordered in cost recovery under B&P §125.3What the rule actually says
The statute says “another state, territory, or any other governmental agency.” It does not require that you were practicing in California, that any California client was affected, or that the other state's rule has a California equivalent. Where the conduct is not a violation here, that affects the penalty, not the cause of action.
Discussion
Analysis, not part of the decision
Arizona's Board of Behavioral Health Examiners disciplined the Arizona license. BBS charged that discipline under §4982.25(a) and the California license was surrendered.
Read the statutory language: “another state, territory, or any other governmental agency.” It does not require that you were practicing in California, that any California client was affected, or that the other state's rule has a California equivalent. Where the conduct would not be a violation here, that goes to the penalty rather than to whether there is a cause of action at all.
The practical implication is about dormant licenses. Clinicians keep an out-of-state license current for the sake of optionality — a possible move, occasional telehealth, an employer's preference — without registering that they are also keeping a second regulator with authority to act, whose action lands here.
Where insurance reaches, and where it does not
Multi-state telehealth practice makes this common and most therapist policies are written for the states listed on the declarations page. If you hold licenses in more than one state, confirm in writing that board defense applies to proceedings before each of those boards, not just the one where you live.
What would have changed it
- Keep track of licenses you are not using. An inactive out-of-state license still generates discipline you must report here, and a renewal you forget is a lapse that can itself be charged.
- If you practice across state lines, know each board's reporting clock. They are not all 30 days.
Questions
For a law and ethics seminar, or for yourself
- You hold a license in a state you no longer practice in. List the arguments for keeping it current and the arguments for letting it lapse.
- Another state disciplines you for conduct that is lawful in California. What is left to argue in the California proceeding?
- How would interstate telehealth practice change your analysis?
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 March 6, 2025, and match the case number in the Formal Disciplinary Actions section. Not legal advice.
