Zegel v. State of Maine, Bd. Of Soc. Work Licensure

CourtSuperior Court of Maine
DecidedApril 30, 2003
DocketPENap-02-15
StatusUnpublished

This text of Zegel v. State of Maine, Bd. Of Soc. Work Licensure (Zegel v. State of Maine, Bd. Of Soc. Work 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
Zegel v. State of Maine, Bd. Of Soc. Work Licensure, (Me. Super. Ct. 2003).

Opinion

STATE OF MAINE © SUPERIOR COURT

PENOBSCOT, ss CIVIL DOCKET DOCKET NO.: AP-02-15 AAA At coor EY N je S gs } ct ya “a LAURA ZEGEL, ) Amo fel 42 Petitioner ) ) . ia ORDERED & ENTERED STATE OF MAINE ) MAY 2005 SUPERIOR COURT BOARD OF SOCIAL ) APR 20 2003 WORK LICENSURE, _) Respondent ) PENOBSCOT COUNTY

Pending before the Court is Laura Zegel’s (the “Petitioner”) appeal from the Maine Board of Social Work Licensure’s (the “Board’’) decision to censure her, place her on probation, and access costs. For the following reasons the Court denies the Petitioner’s appeal.

Background

Ms. Erin Martin filed the original disciplinary complaint against the Petitioner for conduct that occurred while treating with the Petitioner during September of 2000. Before starting therapy with the Petitioner, Ms. Martin called to ask whether she accepted insurance. The Petitioner would not discuss the matter over the phone and informed Ms. Martin that they would discuss payment at the first session. At their first session the Petitioner indicated that there were privacy concerns with paying via insurance. Although Ms. Martin did not agree she agreed to pay without using her insurance. After further consideration Ms. Martin determined that she could not afford therapy without insurance payments. Ms. Martin contacted the Petitioner to discuss the matter and again, the Petitioner would not discuss the matter over the phone. At their next meeting the

Petitioner informed Ms. Martin that she would not treat her if she wished to pay via her

insurance company. Although Ms. Martin wished to continue therapy with the Petitioner she paid for two sessions in cash and terminated the therapeutic relationship.

After terminating the relationship Ms. Martin attempted to get a receipt so she could process her insurance claim. When the Petitioner failed to honor her request Ms. Martin wrote a complaint letter to the Board. Apparently before the Petitioner had notice of the complaint she mailed a receipt to Ms. Martin. Upon receipt Ms. Martin notified the Board and indicated that this “conclude[d] her involvement”. However the Board felt it needed to pursue additional issues. The major issues that the Board identified concemed violations of Section 1.01 and 1.02 of the National Association of Social Worker Code of Ethics.’

After holding initial proceedings and deciding to move forward with the matter, the Board recommended a consent agreement that provided for a censure and six months of consultation on a once-per month basis. The Petitioner declined to execute the agreement and requested a full hearing. On May 9, 2002, the Board held a hearing at which both Ms. Martin and the Petitioner testified. Additionally, the Petitioner called Frederick Reamer (“Reamer”) as an expert witness while the State offered Deborah Sheehan (“Sheehan”) as an expert. Sheehan had been a voting member of the Board during the initial proceedings when the Board decided to forward the matter for a hearing. However, at the time of the hearing she was the Board’s Complaint officer. She was listed as an expert witness and the Board recused her from deliberations on the

matter.

' The Board eventually dismissed the charge concerning section 1.01. Section 1.02 provides: “Social workers respect and promote the right of clients to self-determination and assist clients in their efforts to identify and clarify their goals. Social workers may limit clients’ rights to self- determination when, in the social workers’ professional judgment, clients’ actions or potential actions pose a serious, foreseeable, and imminent risk to themselves or others.” Sheehan testified that in her opinion the Petitioner violated Section 1.02 when she refused to allow Ms. Martin to decide whether to pay via insurance. Reamer testified, based on written materials, that in his opinion the Petitioner did nothing wrong. Reamer then proceeded to answer hypothetical questions that the Board predicated on the facts elicited during the hearing. After the hearing the Board found the Petitioner had not respected Ms. Martin’s right to self-determination. The Board voted to censure her, place her on probation pursuant to 10 M.R.S.A. §8003(5)(A-1)(4), with a condition that she obtain consultation from a licenses clinical social worker twice a month for six months and imposed the costs of the hearing pursuant to 10 M.R.S.A. §8003-D. On May 29, 2002, the Board issued its written decision.

The Petitioner contends that Sheehan’s participation as a Board member and later as a witness violated her right to due process. The Petitioner further contends that the Board’s imposition of a sanction harsher than the sanction in the consent agreement was arbitrary and capricious, that the Board’s imposition of costs without consideration of her ability to pay was arbitrary and capricious, and finally that the Board did not fully explain its reasons behind the sanctions.

Discussion Standard of Review

Courts review an agency’s decision for errors of law, abuse of discretion or

findings not supported by substantial evidence in the record. Consumers for Affordable

Health Care, Inc. v. Superintendent of Insurance et al, 2002 ME 158, 922, 809 A.2d 1233.

The Court limits its review to the record before the agency. M.R. Civ. P. 80(C)(d). The

Petitioner claims that Sheehan’s participation as a witness at the hearing, after having been a voting member of the board during the initial proceedings, violated her due process rights.

Due Process In the administrative setting due process requirements are flexible and do not

entail specific forms or features. Wesson v. Town of Bremen, 667 A.2d 596, 599, n.6,

(Me. 1995). The Law Court has stated that the combination of investigator, prosecutor, and sitting member of the board, created an intolerably high risk of unfairness. Gashgai

v. Board of Registration in Medicine, 390 A.2d 1080 (Me. 1978). The Court in Gashgai

dealt with an individual who had investigated a doctor for an independent body, prepared a report for the body that the Court later suppressed, signed the Complaint for the Board of Registration in Medicine as the acting Secretary and, although he declared himself a non-participant, then sat with the Board during the disciplinary hearing and deliberations while in possession of the suppressed report.

In the present case Sheehan was a member of the Board during the initial proceedings. At the adjudicatory hearing on the matter she acted as the Board’s Complaint Officer, gave testimony, and sat with the Attorney General. Sheehan did not

sit with the Board and recused herself from deliberations. This conduct does not rise to

the impermissible level the Court found in Gashgai. See Frye v. Inhabitants of the Town of Cumberland, 464 A.2d 195, 199 (Me. 1983). Although Sheehan testified before her

fellow Board members, the record does not demonstrate any bias or conflict on the part of

j

the remaining Board members. Sanction

The Petitioner contends that the Board’s imposition of a sanction, greater than the proposed sanction in the consent agreement, was arbitrary and capricious. The Board proposed, in the consent agreement, that the Petitioner admit to two rules violations and face censure, probation, and monthly counseling for six months. After proceeding with a hearing the Board found a single rule violation, censured the Petitioner, placed her on probation and ordered bi-monthly counseling for six months.

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Related

Consumers for Affordable Health Care, Inc. v. Superintendent of Insurance
2002 ME 158 (Supreme Judicial Court of Maine, 2002)
Town of Eagle Lake v. Commissioner, Department of Education
2003 ME 37 (Supreme Judicial Court of Maine, 2003)
Frye v. Inhabitants of Town of Cumberland
464 A.2d 195 (Supreme Judicial Court of Maine, 1983)
York v. Town of Ogunquit
2001 ME 53 (Supreme Judicial Court of Maine, 2001)
Gashgai v. Board of Registration in Medicine
390 A.2d 1080 (Supreme Judicial Court of Maine, 1978)
Wesson v. Town of Bremen
667 A.2d 596 (Supreme Judicial Court of Maine, 1995)

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