Cohen v. State

588 P.2d 313, 121 Ariz. 20
CourtCourt of Appeals of Arizona
DecidedApril 11, 1978
Docket1 CA-CIV 3164
StatusPublished
Cited by6 cases

This text of 588 P.2d 313 (Cohen v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cohen v. State, 588 P.2d 313, 121 Ariz. 20 (Ark. Ct. App. 1978).

Opinions

OPINION

FROEB, Chief Judge, Division 1.

This case involves the effort of appellant to obtain certification in Arizona as a psychologist. In our review of the record and our analysis of the laws and rules relating to certification, we conclude that appellant has been incorrectly denied certification because parts of the certification statutes are unconstitutionally vague and ambiguous and because the Board of Psychologist Examiners has misinterpreted its own rules and the remaining valid portions of the statutes.

A synopsis of the law involved in this appeal seems appropriate at this point. Title 32 (Professions and Occupations), Chapter 19.1 of the Arizona Revised Statutes was passed by the legislature in 1965 and, together with amendments, is found in sections 32-2061 through 32-2087. The laws establish a Board of Psychologist Examiners (§ 32-2062); define certain terms (§ 32-2061); provide the Board with rule-making powers (§ 32-2063); establish qualifications and procedures for certification as a psychologist (§§ 32-2071 through 32-2074); regulate the conduct of certified psychologists (§ 32-2081); provide for hearings (§ 32-2082); recognize certain exemptions (§ 32-2083); bar the practice of medicine by psychologists (§ 32-2084); recognize privileged communications (§ 32-2085), and provide criminal sanctions for certain conduct (§ 32-2087).

[22]*22We are most directly concerned in this case with the provisions relating to certification found in A.R.S. §§ 32-2071 and 32-2072.1 Paragraph 1(c) of § 32-2071 sets forth the academic and degree requirements for certification as a psychologist. It furnishes a standard in general terms which the Board can make more specific by rules enacted under its rule-making power. No professional experience of a given number of years is necessary to meet these qualifications; presumably, a recent graduate with the required academic achievements can obtain certification, provided the academic “credentials” measure up to standards established by the Board.

Section 32-2072 provides, in paragraph D, that if an applicant has three years of professional experience in addition to a satisfactory academic background, “the board shall waive" the credentials examination. Nevertheless, paragraph D requires that an applicant in this category have an academic background equivalent to that of an applicant without three years of professional experience. The only difference is that the applicant need not pass the “credentials examination.”

We shall have more to say about this anomaly; suffice it to state here that the added factor of three years of professional experience has very little impact in the certification process and may well be meaningless under the present statutory scheme.

We turn to the qualifications presented by appellant to the Board. He holds a doctorate of social science (D.S.Sc.) awarded in 1948 by the New School for Social Research located in New York state. The evidence indicates that a Ph.D. is the normal prerequisite for admission to the program at the New School for Social Research but that the Ph.D. requirement was waived because of appellant’s experience and credits. He entered the New School for Social Research after earning an undergraduate degree at Clark University and a master’s degree in psychology at the University of Pittsburgh. As his doctorate degree from the New School for Social Research was awarded in social science, appellant sought certification on the basis that his academic [23]*23training and his degree were the “substantial equivalent” of a “doctoral degree based on a program of studies the content of which was primarily psychological.” See § 32-2071 and § 32-2072.

Appellant’s original application for certification was considered by the Board of Psychologist Examiners on December 14, 1973. It was denied on the ground that his academic training was inadequate. A hearing before the Board, requested by appellant pursuant to § 32-2072(B), was held on March 1, 1974. The Board evaluated the courses shown on appellant’s school transcripts as to whether they fell within the area of psychology. Since the Board found the course titles inconclusive, it asked appellant to contact the schools and obtain descriptions for those courses which he claimed should be categorized as psychological. At a later meeting held on August 7, 1974, the Board considered the materials submitted by appellant and made specific findings concerning the allowed and disallowed course credits.2 The superior court [25]*25denied a trial de novo and, after its review, rejected appellant’s claims and affirmed the order of the Board.

Appellant presents several issues, each of which he contends requires reversal of the decision of the Board of Psychologist Examiners and the judgment of the superior court. In general, these questions relate to (1) the constitutionality of the statutes providing for certification; (2) the validity of rules of the Board; (3) the application of the statutes and the rules by the Board, and (4) the composition of the Board of Psychologist Examiners. We take them up in that order.

Do A.R.S. § 32-2071 and § 32-2072 Violate Due Process of Law Because They are Vague and Ambiguous?

Appellant contends that A.R.S. § 32-2071 and § 32-2072 are so vague and ambiguous that they cannot be understood and they, therefore, deny an applicant for certification due process of law under the state and the federal constitutions. After careful study of these statutes, we partially agree. The certification statutes are set forth in footnote 1.

The statutes involved appear to provide two avenues to certification. One, set forth in § 32-2071(l)(c), is purely academic and the other, set forth in § 32-2072(D), is academic and professional. It would be reasonable to assume that the three years of professional experience called for in § 32-2072(D) would enable applicants having the required experience to be certified with lesser academic credentials than those seeking certification under § 32-2071(lXc). Otherwise, there would be no purpose to § 32-2072(D). Yet, read literally, § 32-2072(D) requires similar, if not identical, academic credentials. The vagueness and ambiguity present in § 32-2072(D), therefore, makes certification uncertain and speculative for an applicant having three years of professional experience and, thus, denies him due process of law. The case of appellant demonstrates this. His professional experience, far exceeding three years, was never an issue in the case.3

Section 32-2072(D) requires a doctor’s degree or its equivalent. Yet, that is also what § 32-2071(lXc) requires. In each case we construe the statute to mean that the degree or its equivalent must be based on “a program of studies the content of which was primarily psychological.” If the doctor’s degree or its equivalent may be based on a program which is not “primarily psychological” but which is substantially equivalent “in both subject matter and extent of training,” then it is wholly unclear what this program might be.

We think our reading of § 32-2071(l)(c) is what was intended by the legislature.

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Bluebook (online)
588 P.2d 313, 121 Ariz. 20, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cohen-v-state-arizctapp-1978.