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Focus on the Facts:  My Experience Writing a Licensing Board Complaint

Nicole Todd

Introduction

I am a victim of therapy abuse. I decided to write a Licensing Board complaint. The Board opened an investigation into the matter, and 15 months later my former therapist permanently surrendered his professional licenses to practice counseling in my state. I am grateful for the outcome and aware that it is atypical. I am continually frustrated by the fact that complaints written by other therapy abuse victims do not have similar resolutions. Regardless of the facts and how they are presented, there is no way to guarantee  the outcome of a complaint simply because so many variables are involved. Every victim's circumstances are unique. Licensing Boards operate differently, depending on the state and profession involved. Every abuser is different, and many appear to be so impressive and credible that Boards seem reluctant to act at all. Though there were several other forces at work, including luck, I think that the way my complaint was written made a difference in the outcome.

Initially, I did not see psychotherapy as a business regulated by a State agency. I did not realize that Licensing Boards protect consumers of psychotherapy in the same way that they protect consumers of more traditional businesses:  by ensuring that only qualified people are licensed to practice a profession. Therapy seemed like an intensely private matter. If a carpenter botches a roof installation, or a car mechanic wrecks an engine repair, the damage done is obvious. But if a therapist mauls a client's psyche, the harm done is intangible and difficult to describe. Most victims do not report therapy abuse because they are confused, fearful, and ashamed.

Focus on the Facts

Above everything else, a Licensing Board complaint should be a clear, concise description of the facts. It should be a succinct account of your experience. It should balance detail with brevity. Keep in mind that Board members are  licensed  professionals who volunteer their experience and time. The fact is that long, rambling complaints risk not being read throughly. A complaint should not be a legal brief, dramatic recollection, or a historical document. It should not be an attempt to lecture or educate the Board. Do not try to make sense of it. And do not attempt to explain it—that is the job of your former therapist.

The Fact-Finding Mission

Initially, I had trouble focusing on the facts. For a long time, I was not even exactly sure of what had taken place. My experience seemed so crazy, so outside the realm of typical human experience, that I wondered if it actually happened. I thought I must have exaggerated things, or even imagined them because I could not make sense of it. I became distrustful of myself, my memory, my perceptions and my general understanding of how the world worked. I felt disoriented and fearful. It was as if my internal compass had broken and I could not get my bearings back. I was lost, and I could no longer trust myself. My main focus was not on facts, but on how I felt about them. Mere facts seemed so tiny and insignificant compared to the overwhelming emotions I felt. I was unsure if I had accurately recalled many events. I questioned each one of those until I was sure my perception was as accurate as it was ever going to get. Did he really say this to me?  Had that actually happened?  Did I really see this?  Did he really do that?  Gradually,  I began seeing the facts.

Collect the Facts and Arrange Them in Chronological Order

I began by jotting down memories for my eyes only. Though I wasn't sure what I would do with it all,  I needed to write down everything that came to mind and keep it all in one place. This was cathartic, and jump-started my memory. I began remembering details I had forgotten. I then arranged things in chronological order as best as possible. This was the backbone of my complaint.

Review State Laws and Regulations

I gained confidence in my belief that something went seriously wrong with my therapy by browsing through the Licensing Board's set of laws and regulations regarding professional conduct. I got a sense of what kind of facts were relevant to the Board. I began recognizing the many ways I had been abused  from the explicit descriptions of the rules and how they are broken. It was a relief to find that there were actually words for what had happened. I found valuable information describing professional misconduct, sexual misconduct, client confidentiality, and termination of services. I had done nothing wrong as a client. Regarding sexual misconduct, something resonated with me when I read that consent on the client's part is never allowed as a defense for sexual contact. My therapist's behavior was in question here, not mine.  As a client, I had done nothing wrong.

Understand the Basics of Psychotherapy

I also read up on the fundamentals of psychotherapy and  therapy abuse. Therapy is a very lop-sided relationship. There are hidden forces at work in psychotherapy that render a client virtually helpless. A therapist is completely responsible for managing those forces. No amount of education or intelligence protects clients from therapists who abuse that power. I had difficulty understanding the concept of power-imbalanced relationships, and even more difficulty realizing that I had actually been in one. My therapist and I had never been on equal footing. Only much later did I realize the full extent of his power over me.

I also had difficulty understanding the role of transference. I only understood that I had fallen in love. The fact that I had fallen in love with my therapist during the course of therapy seemed inconsequential. My feelings were real, but the situation that created them was not. My therapist had cultivated my feelings like a tender plant in a greenhouse. Transference gave him the power to easily lead me places I never would have gone otherwise.

Boundary violations were easier to understand than transference. I quickly became addicted to how special and lovely they made me feel. I did not feel their devastating impact until months later. They seemed insignificant at first, hardly worth writing down in my collection of facts. Though they began in tiny increments of seemingly harmless behavior, they grew increasingly large and reckless. Boundary violations were really more of a process than separate events. Arranged chronologically, I saw that they took on the momentum of a runaway train.

A Checklist of Facts to Include in a Complaint

The following is a list of suggestions to incorporate in a Licensing Board complaint.

  • The therapist's name and type of license

  • When and how the professional relationship began

  • The original understanding of the services to be performed and the arrangements for payment

  • How things went at first

  • When and how things began to change. Comments on how you felt about the changes at the time and/or that much later you looked back on it and realized it was not okay.

  • A chronology of examples of problematic behavior. It the list is long don't include every occurrence, but be clear that there are more—e.g. “on numerous occasions he...” or “several times he...”

  • When and how the relationship ended

  • A clear, brief statement on how you have been affected

  • A clear statement that you are willing to answer questions/elaborate

Additional Suggestions

Collect the evidence (such as correspondence, gifts, receipts, diaries, eyewitnesses, etc). I didn't have much physical proof. But I did have lots of details about the abuse and my therapist's personal life. I also had credibility. At one point in the investigation, the Board asked me to appear to answer additional questions. I answered them truthfully. My former therapist denied almost everything. The truth has a certain ring to it, and I believe my therapist's responses had the unintentional effect of enhancing my credibility at the expense of his.

If you have mixed feelings about your therapist, or want to acknowledge the positive along with the negative, then say so. The experience was probably not all bad, which is one of the reasons why therapy abuse is so confusing to victims.

Use neutral language. Write as if you are a journalist.  Do not lecture and avoid sarcasm. Save the emotional words for your impact statement.

Make the complaint easy to read and follow. Type it up carefully, and avoid small print. Organize it into sections, and use headings.

Writing a complaint can be emotionally draining. Consider ways to protect yourself. For example, after spending two hours writing, take a break and do something you enjoy. Otherwise, the complaint process may begin feeling like the abuse did—out of your control and consuming your life.

After your complaint is sent, let it be. As a consumer, you have done a public service by reporting the facts to a state entity with the power to take action. The process is now out of your hands. Licensing Boards move slowly. Their actions reflect their willingness to protect consumers by policing their profession. At the very least, complaints put abusers officially “on the record”. This is an unpleasant, embarrassing consequence for any professional.  Having a complaint on file will likely make an abuser think twice next time. If other victims file a complaint, they will be helped by yours.

The Rewards of Writing a Complaint

I've learned a great deal about psychotherapy and the dynamics of power-imbalanced relationships.  Abusive professionals can destroy the lives of the very people they pose to help. I was ashamed of what had happened, and blamed myself.   Writing a complaint helped me put the blame where it belongs.  My therapist was entirely responsible for what had happened between us.  I had done nothing wrong by holding him accountable for his actions.

After the abuse,  I began falling to pieces. I was sure that my psychological disintegration would end in self-annihilation. Unlike my former therapist, I could not  put it all behind me and move on. I had been injured on a primal level, and my instincts came from the same deep place. Before I understood what to call it, I knew something seriously wrong had happened to me. Before I realized why, I felt outraged.  Before I decided  how, I knew I would tell others what happened. Though I was hurt and confused, I could still listen to my instincts.

Finding the facts meant sorting through the destruction to discover what was real. The abuse left me in an emotional maelstrom. Fact-finding was painful and exhausting. But, the process had the benefits of being cathartic and validating. I had not misunderstood reality. I did not make it up. My experience sounded bizarre because  it really was. By finding the facts,  I also began finding what I had lost—the ability to trust myself.

My awareness of other people has grown.  There are dangerous people who are armed with an arsenal of phenomenal acting skills.  They appear kind, trustworthy, caring, and compassionate. Their appearance is a performance designed to manipulate others. They exude a warmth and charm that belies their reptilian nature.  They routinely exploit and discard others, never taking responsibility for the obliterated lives they leave behind.  When I meet people like this now, I recognize them. Though I cannot pinpoint it, there is something not quite right about them. I trust my instincts and keep my distance.

Sexual abuse by psychotherapists is without defense.  If I had I said nothing, I would have betrayed myself.  My therapist would have suffered no consequences. I think that Licensing Boards need to know if a professional poses a danger to the public.  My therapist never believed that I would tell another soul about what happened, much less a group of his professional peers.  He seriously underestimated my strength.  I discovered that I did too.

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