Case library · California · 2023–2026
What actually gets a California therapist disciplined
In short
Forty-eight real cases, the exact code section each was charged under, and what each one cost
48 written up in fullReal BBS decisions, de-identified. What happened, what it was charged under, and what it cost.
The shape of itThe forty-eight casesWhat it costsInsurance that answers for it
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 in the first collection 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 those 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
Forty-eight 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, where a liability policy does and does not reach, a discussion of what the Board was deciding, and three questions for a class.
Boundaries — sexual contact and the drift short of it — and criminal convictions are the two halves of this library. Only a handful began as a complaint about clinical work. The pattern to take from this is that discipline usually arrives from outside the therapy room, through a conviction feed, an employer, another licensing board, or an application form.
Showing all 48 cases
Sexual boundaries · 8
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$8,039Four employers acted on him before the Board ever didA 2010 suspension, a 2017 forced resignation, a 2020 termination and a 2021 improvement plan — all internal, none reported.AMFTMarch 9, 2023Surrendered$33,704He dosed two clients with MDMA and psilocybin, then slept with oneBoth relationships began before there was a therapy relationship — one in a classroom where he was the teaching assistant.LMFTMarch 9, 2023Surrendered$14,486Boundary drift with no sexual contact · 5
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$8,107Alcohol at lunch, then a session and a groupFour years of probation, total abstinence, random testing at his own cost, and $5,190.LMFTJuly 24, 2025four yrs probation$5,190.00Records, confidentiality and the file · 3
All 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 · 4
One of these 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, 2026RevokedTwenty-two sessions billed for a patient seen twiceOne payor’s audit found $35,329 in overcharges across 559 claims; she repaid it, then shredded the files.LMFTMay 18, 2023Surrendered$32,956Discipline that arrives from somewhere else · 6
All 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 reprovalPsychology board probation reaches a second licenseThe 30-day duty to report the first board’s discipline became its own cause for discipline.LEPJuly 24, 2025three yrs probation$2,000.00A year of abuse disclosures, no report filedThe psychology board heard the evidence and imposed probation; the BBS case ended in surrender.LMFTMay 15, 2025Surrendered$3,854.00Fitness-to-practice examinations · 1
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, and the duty to report one · 10
The largest category in the data by a wide margin — sixty-two of the 103 decisions cite §4982(a), and most of those are a DUI arriving through the Department of Justice notification feed rather than through a client. Only a few DUIs are written up in full, because past the first they repeat. What is here instead is the range: the modal case, the duty to report a conviction inside thirty days, the convictions that have nothing to do with a client at all, and the cases the Board decided on its own evidence packet because nobody filed a notice of defense.
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$2,578Charged 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$5,083A felony assault conviction, and no answer to the BoardHe filed no notice of defense within 15 days; the Board decided the case on the papers and revoked.APCCMay 18, 2023Revoked$4,551.25A battery conviction ends an associate’s registrationShe never filed a notice of defense, so the Board decided the case without her.ASWMay 18, 2023RevokedFelony child endangerment, and no answer to the BoardShe filed no notice of defense, so every allegation was taken as true and the registration was revoked by default.ASWDecember 14, 2023RevokedA 0.15 breath test and two missed 30-day deadlinesShe won a probation lighter than the Board’s own guideline minimum, then surrendered the registration less than two years into it.AMFTDecember 14, 2023SurrenderedA drive-through altercation, then no answer to the BoardHe never reported the conviction, never answered two letters, and never filed a notice of defense; the registration was revoked without a hearing.AMFTAugust 15, 2024Revoked$2,597.50Applying with a record · 5
The Board is not deciding what somebody did in a session. It is deciding whether to let them start at all. §480 lets it look back seven years — except for a serious felony under Penal Code §1192.7, where there is no time limit at all, and where §1192.7(c)(23) sweeps in any felony involving a weapon. What the statute will not let the Board do is refuse on the conviction type alone: §493 requires the rehabilitation analysis in 16 CCR §1813 every time. Read these for what that analysis actually accepts.
Two nursing board actions, then an MFT applicationThe Board denied the application, then agreed to issue the registration under two years’ probation and a recordkeeping course.AMFTJuly 24, 2025ProbationShe wrote her supervisor’s name on the hours formsThe Board revoked her registration, granted her a new one on three years’ probation, and cut the cost award from $10,650 to $3,000.APCCJanuary 18, 2024Probation$3,000.00A 34-year prison sentence, then a social work applicationThe Board denied the application, then settled by issuing the registration under five years’ probation and a psychological evaluation.ASWMarch 6, 2025ProbationA 1985 murder conviction, and a 2024 registration on probationThe judge found cause to deny and granted the application anyway: nearly 40 years, a clean parole, and a master’s degree in counseling.APCCAugust 15, 2024five yrs probationA 2008 conviction still reached a 2024 applicationThe seven-year lookback in section 480 does not apply to serious felonies; the registration issued on three years of probation.ASWDecember 4, 2025three yrs probationWhat happens after discipline · 6
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$3,432Her registration lapsed while she was on probation for itNo new clinical misconduct — one administrative condition breached turned three years of probation into forty-two months.AMFTdate not legibleProbationFalsified course certificates end a stayed revocationMost of the violations were curable; typing her own certificates of completion was not.LMFTJune 13, 2024RevokedEight weeks without a therapist, and a year added to probationThe gap opened when her own Board-approved therapist became unavailable, and the Board counted it as a violation anyway.ASWSeptember 28, 2023Probation extendedWhat 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 them 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.
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.
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.
