Cobb v. State of Maine, Bd. of Couseling Prof'ls Licensure

CourtSuperior Court of Maine
DecidedJanuary 12, 2005
DocketCUMap-03-05
StatusUnpublished

This text of Cobb v. State of Maine, Bd. of Couseling Prof'ls Licensure (Cobb v. State of Maine, Bd. of Couseling Prof'ls Licensure) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cobb v. State of Maine, Bd. of Couseling Prof'ls Licensure, (Me. Super. Ct. 2005).

Opinion

STATE OF MAINE

SUPERIOR COURT CUMBERLAND, ss.

CIVIL ACTION DOCKET NO. AP-03-05 y EO OYUN AMA d¢0 “

(5 JAN 12 DB ox yq A. MICHELLE COBB,

Plaintiffs Vv. ORDER ON 80C APPEAL STATE OF MAINE, s BOARD OF COUNSELING merase my fe PROFESSIONALS LICENSURE mes os . Defendants. ~ os “gg? FACTUAL BACKGROUND FALIVAL BACKGROUND

This matter was previously before the court on petitioner’s first 80C petition for judicial review of a Decision and Order of December 26, 2002 of the State of Maine Board of Counseling Professionals Licensure (the Board). To the extent that it remains unchanged, the following factual background is taken from this court’s order, dated December 22, 2003 in which the court remanded the case to the Board.

Petitioner, a Licensed Professional Counselor, counseled the two minor sons of a divorced couple. In doing so, petitioner diagnosed the children with certain conditions and submitted forms to the children’s father’s insurance company in which she filled out diagnostic codes taken from the Diagnostic and Statistica] Manual (4th edition) (DSM-IV). In her submissions to the insurance company, Petitioner filled in the “Diagnoses or Nature of Illness” portion with the numbers 309.3 and 313.81 from DSM-

IV. Those numbers denote conditions known as “Adjustment Disorder with Disturbance of Conduct” and “Oppositional Defiant Disorder,” respectively. The insurance company paid petitioner for this counseling. Subsequently, the parents of the children filed a complaint on March 21, 2001, regarding the Petitioner’s diagnoses of the children. An investigation took place resulting in charges being brought against Petitioner for diagnosing the children’s mental health conditions in violation of 32 M.R.S.A. § 13858 (2002) *, and for fraud and deceit.

After lengthy administrative hearings, the Board dismissed the fraud and deceit charges. The Board found, however, that Petitioner violated section 13858, disciplining her by censure, fine, and thirty hours of supervision. Petitioner then sought judicial review of that final agency action pursuant to M.R. Civ. P. 80C. After considering the parties’ arguments, this court held, inter alia, that the Board’s interpretation of 32 M.R.S.A. § 13858 was correct such that Petitioner, as an LPC, was not authorized under the statute to diagnose and treat mental health disorders. Cobb v. Me. Board of Counseling Professionals Licensure, PORSC-CV[sic]-03-05 (Me. Super. Ct., Cumb. Cty., Dec. 22, 2003). Furthermore, because it concluded that the Board’s interpretation of the statute comported with the statute’s plain language, this court rejected petitioner's argument that the Board, in disciplining her, had engaged in unlawful rulemaking. This court found that in disciplining petitioner under the statute, the Board had simply engaged in well-supported statutory interpretation and application rather than having created a “regulation, standard, code, statement of policy, or other agency statement of general applicability,” 5 M.RS.A.§ 8002(9), in an adjudicative proceeding. See Cobb v. Me. Board

of Counseling Professionals Licensure, PORSC-CV[sic]-03-05 (Me. Super. Ct., Cumb. Cty,

" Section 13858 provides that there are three specific clinical licenses offered by the Board which have equivalent clinical status. The statute further states that clinical status authorizes an individual to diagnose and treat mental health disorders. The three specific licenses, licensed clinical professional counselor, licensed pastoral counselor, and licensed marriage and family Dec. 22, 2003). This court also recognized, however, that the statute does not define “mental health disorder” and consequently found that the Board’s exclusion of testimony regarding the meaning of “mental health disorder” as used in section 13858 was error. Because it is necessary to understand what the term “mental health disorder” means under the statute, before deciding whether petitioner did in fact diagnose mental health disorders, this court remanded the case to the Board for additional evidence regarding the meaning of that term and whether the conditions Petitioner diagnosed constituted “mental health disorders.” Id.

In accordance with this court’s order, the Board held a hearing on June 21, 2004 during which it considered testimony regarding the meaning of the term “mental health disorder.” Following that hearing the Board concluded that the conditions deemed “mental health disorder” in the DSM-IV may be considered “mental health disorders” under section 13858. It also found that the DSM-IV designations referenced by the Petitioner in her treatment notes and submissions to the insurance company, constituted “mental health disorders.” Consequently, the Board again found that

petitioner violated section 13858 by diagnosing mental health disorders without being

licensed to do so.

Petitioner now seeks judicial review of the Board’s decision.

DISCUSSION

As stated in this court’s December 22, 2003 order, this court will reverse or modify the administrative decision of the Board only if the administrative findings,

inferences, or conclusions are:

therapist, are authorized by statute to diagnose and treat mental health disorders. See 32 M.R.S.A. § 13858. Licensed professional counselor is not included in that list. (1) In violation of constitutional or statutory provisions; (2) In excess of

the statutory authority of the agency; (3) Made upon unlawful procedure;

(4) Affected by bias or error of law; (5) Unsupported by substantial

evidence on the whole record; or (6) Arbitrary or capricious or

characterized by abuse of discretion.

Hale-Rice v. Maine State Ret. Sys., 1997 ME 64, § 8 691 A.2d 1232, 1235 (quoting 5 MLR.S.A. § 11007 (1989)). The agency’s interpretation “is entitled to great deference and will be upheld unless the statute plainly compels a contrary result.” Centamore v, Dep’t of Human Services, 664 A.2d 369, 370-71 (Me. 1995) (internal quotation omitted). The Superior Court should not second-guess the administrative decision of the agency unless “the agency’s conclusions are unreasonable, unjust or unlawful in light of the record.” Imagineering, Inc. v. Dep't of Prof'l & Fin. Regulation, 593 A.2d 1050, 1053 (Me. 1991).

Petitioner argues that both the original decision of the Board and the decision made on remand from this court should be vacated for a number of reasons. Petitioner argues: (1) that the Board’s interpretation of section 13858 to prohibit an LPC from diagnosing mental health disorders was arbitrary and capricious; (2) that the Board prosecuted the petitioner on the basis of rules not adopted pursuant to the Maine Administrative Procedure Act: (3) that the Board is estopped from prosecuting the petitioner for diagnosing mental health disorders because the Board’s own conduct induced her to act and she reasonably relied, to her detriment, on the Board’s conduct; (4) that prosecution of the petitioner by the Board violated her right to due process; (5) that the Board’s imposition of costs against petitioner was arbitrary and capricious; and (6) petitioner should be awarded attorney’s fees under 42 U.S.C. § 1988,

Because the court addressed many of petitioner’s arguments in its December 22,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

International Paper Co. v. Board of Environmental Protection
1999 ME 135 (Supreme Judicial Court of Maine, 1999)
Centamore v. Department of Human Services
664 A.2d 369 (Supreme Judicial Court of Maine, 1995)
Bangs v. Town of Wells
2003 ME 129 (Supreme Judicial Court of Maine, 2003)
Hale-Rice v. Maine State Retirement System
1997 ME 64 (Supreme Judicial Court of Maine, 1997)
Imagineering, Inc. v. Superintendent of Insurance
593 A.2d 1050 (Supreme Judicial Court of Maine, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Cobb v. State of Maine, Bd. of Couseling Prof'ls Licensure, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cobb-v-state-of-maine-bd-of-couseling-profls-licensure-mesuperct-2005.