A Pennsylvania Court has determined that a psychologist must formally terminate a therapeutic relationship before engaging in sexual activity with the patient. The clinician's suggestion to his patient, made after the sexual relationship began, that she see another psychologist did not constitute termination.

Psychologist Roger Morris conducted the last paid therapy session with his female patient in October of 1989. He allegedly sat next to her on the couch, held her hand and told her he loved her. This behavior was preceded by a pattern of therapy sessions that lasted longer than usual and included personal self-disclosures by the therapist. He reportedly had begun to socialize with the patient and have dinner together. After the last therapy session, Dr. Morris began to have sexual relations with the woman.

The State Board of Psychology [hereinafter the Board] revoked his license after finding that he breached his ethical duties to the patient, thereby violating the Professional Psychologists Practice Act. Dr. Morris appealed, arguing that he did not violate the Act because he had terminated the therapeutic relationship with the patient, and sexual relations with former clients are not prohibited.

The Court disagreed, finding that Dr. Morris had not terminated the relationship with his patient merely by ceasing to bill her. Furthermore, his suggestion to her regarding further treatment did not occur until after the sexual relationship was well under way. The findings of the Board were affirmed.