Andrews v. Board of Social Worker Licensure

Superior Court of Maine·Decided September 2, 2005·No. CUMap-05-008·Unpublished

Opinion

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Petitioner appeals pursuant to 5 M.R.S.A. § 11001 and M.R.Civ.P. 80C from the Board of Social Worker Licensure's (the "Board") decision, which found that Petitioner had violated the Code of Ethics of the National Association of Social Workers (the "NASW Code").

STATEMENT OF FACTS

Petitioner is a licensed clinical social worker. R. at 76. She obtained her Masters Degree in Social Work in 1999, and began practicing part-time in January of 2001, and then full-time in September of 2003. Id. She voluntarily receives supervision in her practice from two other social workers. R. at 78.

Approximately two weeks before September 22, 2003, Petitioner received a phone call from Melissa Whte, who is the mother of two boys, born in 1993 and 1995. I d . In this conversation, Ms. White told the Petitioner that she shares custody of the two boys with her ex-husband, Jeff Bailey. She then explained

1 Petitioner did not ask for, and was not given a copy of Ms. White's and Mr. Bailey's December 2, 1997 divorce judgment. Over Petitioner's counsel's objection, the judgment was entered into the record at the hearing. It states in part:

that the boys appeared "stressed out" after returning from their week with their father, and that she thought somebody outside of the family should see them. R. at 78-79. Based on this information, Petitioner scheduled an initial assessment for the boys for September 22. R. at 79.

On September 22, Ms. White brought the boys to see Petitioner, and Petitioner had her sign an informed consent form. R. at 93. Petitioner considered this initial assessment as the beginning of her services to the children. Id. After this initial assessment, the Petitioner scheduled a phone conference with Ms. White for September 30,2003, and planned to obtain contact information for Mr. Bailey at that time. R. at 82 and 94. However, Mr. Bailey called Petitioner on September 29, and expressed his frustration that he had not been contacted before Petitioner had seen the chldren. R at 66-67 and 82. The Petitioner and Mr. Bailey disagreed about whether she should hand over to him a copy of her progress notes from her session with the boys. See R. at 83. Although Petitioner acknowledged Mr. Bailey's right to obtain a copy of these notes, she explained to Mr. Bailey that she felt that turning over the notes to him would jeopardize the therapeutic relationship. R. at 83. Based on Mr. Bailey's request for copies of the progress notes, Petitioner informed Ms. White on September 30, at their scheduled phone conversation, that she would not continue therapy with the children. R. at 85.

The parties shall share parental rights and responsibilities with respect to the minor children. Shared parental rights means that most or all aspects of the child's welfare remain the joint responsibility and right of both parents, so that both parents retain equal parental rights and responsibilities and both parents must confer to make joint decisions regarding the child's welfare. Matters pertinent to the children's welfare include, but are not limited to, education, religious upbringing, medical, dental and mental health care, travel arrangements, child care arrangements and residence. Parents who share parental rights and responsibilities shall keep the other informed of any major changes affecting the children's welfare and shall consult in advance to the extent practicable on decisions related to the children's welfare.

On November 13, 2003, Mr. Bailey filed a complaint with the Board stating that Petitioner had interviewed his children and agreed to services without seehng his input or agreement, and alleged that this violated his right as a parent with shared parental rights to gtve consent for his chldren's therapy. R. at 1.

The Board conducted a hearing on December 10, 2004, in order to determine whether or not Petitioner's actions, which are factually undisputed, were in violation of her ethical duties to obtain informed consent prior to commencing services. 32 M.R.S.A. § 7059(1)(E)allows the Board to suspend or revoke a social worker's license for any gross negligence, incompetency, or misconduct in the practice of professional social work. 02-46 C.M.R. Chapter 4(3) sets forth grounds for discipline of social workers. 02-46 C.M.R. 4(3)(3)(G) includes within the definition of "gross negligence, incompetency, or misconduct," engaging in conduct which violates the NASW Code. Section 1.03 of the NASW Code outlines a social worker's responsibility to obtain informed consent. Subsections (a) and (c) of this provision are applicable to situations in which the social worker is treating chldren. They state:

(a) Social workers should provide services to clients only in the context of a professional relationship based, when appropriate, on valid informed consent. Social workers should use clear and understandable language to inform clients of the purpose of the services, risks related to the services, limits to services because of the requirements of a third-party payer, relevant costs, reasonable alternatives, clients' right to refuse or withdraw consent, and the time frame covered by the consent. Social workers should provide clients with an opportunity to ask questions.

(c) In instances when clients lack the capacity to provide informed consent, social workers should protect clients' interests by seelung permission from an appropriate third party, informing clients consistent with the clients' level of understanding. In such instances social workers should seek to ensure that the third party acts in a manner consistent with clients' wishes and interests. Social workers should take reasonable steps to enhance such clients' ability to give informed consent.

At the hearing, Petitioner stated that, from her training, she understood that she did not need to obtain consent from both parents in order to begn services for a child, but that consent from one parent would be sufficient. R. at 95. She also stated that it was her understanding that, even when worlung with divorced families, one parent cannot necessarily veto the decision of another parent if one parent decides to make a decision about treatment of any lund. R. at 96-97.

The Board by a vote of 5-0 found that Petitioner's actions were in violation of the above sections because she did not obtain Mr. Bailey's consent prior to providing services to the children. R. at 35. Pursuant to h s finding, the Board put Petitioner's license on probation and ordered her to attend and pay for six hour-long sessions with a licensed clinical social worker on the topic of professional ethcs.

On February 14,2005, Petitioner moved the Board for a stay of enforcement of the Board's decision, which was denied by the Board on March 21, 2005. Petitioner filed separately in Superior Court for a stay of enforcement, which request was denied on May 9,2005.

On appeal, Petitioner contends that the Board's interpretation of the NASW Code is erroneous as a matter of law, that the standards for informed consent upon whch the Board based its decision were so vague as to violate petitioner's right to due process of law under the Constitutions of the United States and the State of Maine, and that the Board failed to adduce sufficient proof of the standard by whch Petitioner's conduct in t h s matter was to be judged such that its decision was unsupported by any substantial evidence in the record.

STANDARD OF REVIEW

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Andrews v. Board of Social Worker Licensure, (Me. Super. Ct. 2005).

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