The Tribunal case of Psychology Board of Australia v Angelakis ([2024] SACAT 24) is a significant disciplinary ruling involving a psychologist who engaged in professional misconduct by violating ethical boundaries with a former client. The South Australian Civil and Administrative Tribunal (SACAT) found Dr. Samantha Angelakis had engaged in multiple instances of professional misconduct including boundary violations, an inappropriate sexual relationship, and providing false information to regulatory authorities.
This article examines the key lessons from the case, offering insights for health practitioners on maintaining professional boundaries, ethical obligations under the Australian Psychological Society (APS) Code of Ethics, and the consequences of practitioner misconduct.
Key Facts of the Case
Dr. Angelakis, a clinical psychologist, treated a police officer (“CA”) for work-related PTSD between April and July 2019. Following the termination of therapy, she entered into a sexual relationship with him within two days of the final session. The Tribunal found her guilty of:
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Failing to maintain professional boundaries (Ground 1).
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Engaging in a sexual relationship with a former client within two years (Ground 2).
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Providing false/misleading information to AHPRA and the Board (Grounds 3 & 4).
Key Lessons for Health Practitioners
1. Maintaining Professional Boundaries is Non-Negotiable
The Tribunal found that Dr. Angelakis blurred boundaries by:
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Engaging in personal and non-clinical communications (e.g., sharing personal emails, discussing social activities). It was notable that Dr. Angelakis has shared her personal email account to her client and there were threads of discussion of social activities that had a personal and non-therapeutic character.
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Flirtatious and sexualised exchanges (e.g., joking about seeing CA in uniform, referencing romantic films). It was relevant that in the two weeks leading up to the cessation of the therapeutic relationship, the email correspondence was increasingly flirtatious in nature.
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Socialising outside therapy (e.g., gym sessions, coffee meetings). On the evidence, Dr. Angelakis commenced socialising with the client immediately after the termination of the professional relationship.
There are a number of key lessons to be learned from this element of the case:
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Strictly uphold professional boundaries—if a client seeks personal connections, reinforce boundaries immediately. The Tribunal affirmed that Dr. Angelakis’ failure to uphold professional boundaries with her client constituted breaches of Clauses B.3 (g) and C.3.1 of the APS Code of Ethics. Interestingly, the failure to uphold boundaries alone (in circumstances where the client had disclosed matrimonial problems) was also found by the Tribunal to in itself have constituted professional misconduct p[107].
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Seek supervision— the Tribunal accepted the evidence of the independant expert that Dr. Angelakis’ failure to seek supervision in relation to the changing client relation was a key element in its ultimate finding that Dr. Angelakis had engaged in professional misconduct p[90].
2. Prohibition on Sexual Relationships with Former Clients
The APS Code of Ethics (Clause C.4.3) prohibits sexual relationships with former clients within two years of ending therapy. The Tribunal found that Dr. Angelakis breached this rule by initiating an intimate relationship the day after therapy ended. The lessons are not complex:
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Strict adherence to ethical guidelines is required—no exceptions.
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Document and report if a client expresses romantic interest to mitigate risks.
Given the particular clarity of the factual background and the concessions of the respondent party, the Tribunal did not dwell on this ground as it was not contested.
3. Honesty with Regulatory Authorities is Crucial
It was alleged by the Psychology Board that Dr. Angelakis:
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Delayed reporting the relationship by six months.
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Provided misleading statements about when the relationship began.
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Deleted emails to conceal evidence.
The Tribunal on a fulsome consideration of all the evidence, concluded that, Dr Angelakis had knowingly misled the Board, worsening her misconduct. There are key lessons to be learned from this element of the case:
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Mandatory reporting must be timely and accurate. The Tribunal took a very low view of Dr. Angelakis’ delay stating at paragraph [177]: “We do not accept the respondent’s stated reasons for the delay in notifying the Board of her conduct. We consider that the extraordinary delay is corroborative of her intent to mislead.”
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Do not conceal or downplay violations—transparency is critical. The Tribunal was similarly scathing of the content of the ambiguity of Dr. Angelakis’ responses stating at paragraph [178]: “(A)t the very least, the evidence supports her being reckless as she ought to have known that her statements were not correct. We find it incredible that she would not have remembered the contents of the emails.”
4. The Consequences of Professional Misconduct
The Tribunal characterised Dr. Angelakis’ conduct as “substantially below” professional standards and constituting professional misconduct, necessarily warranting disciplinary action.
The Tribunal also made additional (arguably unnecessary) comments relating to Dr Angelakis’ evidence, stating at Paragraph [183]:
We did not find Dr Angelakis to be a satisfactory witness. Throughout her evidence, she was on crucial issues vague, evasive, projecting (deflecting initiative for the relationship on CA) and at times, seemingly insight less as to her conduct at the relevant times. She displayed a tendency to minimise her conduct and to defer to the benefit of hindsight when the gravity and consequences of that conduct would have been patently obvious to any reasonable, ethical practitioner of any standing, let alone a psychologist specifically trained in trauma management and entrusted with the care of a vulnerable client, including CA (who presented with multiple co-morbidities) at the time of treatment. Overall, Dr Angelakis was neither a credible nor reliable historian of the facts and our findings reflect so accordingly.
Interesting, this position was softened in on appeal to the South Australian Supreme Court in Angelakis v Psychology Board of Australia [2024] SASC 133 (27 November 2024), wherein the Honourable Justice B Doyle held, variously:
[406] Ethical obligations are uncompromising, but life is complicated. Nothing could be clearer than that the connection formed between the appellant and CA was powerful and mutually felt. That connection has, it seems, been enduring….
[408] Notwithstanding the conclusions I have reached on the grounds of appeal, the fact remains that the appellant did, ultimately, self-notify and has embarked in a conscientious way on a process of mentoring and self-reflection. Although some issues were contested before the Tribunal, the appellant made significant concessions. The ethical transgressions the subject of the notification would appear to have been an aberration in an otherwise promising and worthwhile career. These will be matters for the Tribunal to consider in the context of the principles informing the imposition of appropriate sanctions under the National Law.
At the date of publication of this article there is no published decision on the sanctions associated with the decision.
Conclusion: Upholding Ethical Standards
This case underscores the importance of maintaining clear professional boundaries, adhering to ethical guidelines, and being timely and truthful with the regulator. Health practitioners must:
- Avoid personal relationships with clients;
- Uphold professional boundaries in all circumstances;
- Report ethical breaches promptly;
- Be forthcoming and honest in their correspondences with the Regulator; and,
- Seek guidance when unsure about boundaries.
