Ontario disciplinary panel suspends therapist for conflict of interest in dual relationship

A panel of the Ontario Registered Psychotherapists Discipline Tribunal imposed a five-month suspension on a registrant who engaged in a dual relationship with two clients who were mother and child, resulting in a conflict of interest. 

In College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v LeBeau, 2025 ONRPDT 5, the College alleged misconduct by a therapist who furnished therapeutic services to two clients while in a dual relationship with them, as well as therapeutic treatment to these clients without obtaining the necessary consent. 

The parties provided a statement of uncontested facts. Client A and her husband, Mr. X, had a child, Client B. The family members were the registrant’s neighbours and friends. 

In October 2020, the registrant provided two in-person therapeutic sessions to Client A, who was undergoing grief and a mental health crisis amid her mother’s declining health. 

Also in 2020, the registrant delivered six in-person therapeutic sessions to Client B, who was experiencing anxiety. In June 2022, the registrant furnished another session to Client B. 

The registrant invoiced and received payments for the services delivered to both clients. The registrant asked them to sign a statement acknowledging that she was not acting as their therapist or providing them with active therapy. 

Client A and Mr. X separated in November 2022. By early 2023, the registrant entered into a romantic relationship with Mr. X. 

The registrant pleaded no contest to the misconduct allegations. She did not contest that: 

• She provided therapeutic services to Clients A and B, while in a dual relationship with them that constituted a conflict of interest 
• She inappropriately commenced a romantic relationship with Mr. X in early 2023, given her previous therapeutic relationships with Clients A and B in 2020 and 2022 
• The consents to treatment stating that she was neither acting as a therapist to Clients A and B nor providing them with active therapy were invalid 

The parties provided a proposed joint submission regarding the penalty and costs. 

Therapist suspended

As the parties had requested, the panel suspended the registrant’s registration certificate for five months and imposed conditions and limitations on the certificate, a reprimand, an individualized professional ethics and boundaries course, and costs of $4,700. 

The panel noted that it should meet a high threshold – specifically, it should determine that the proposed penalty would bring the administration of justice into disrepute or would not serve the public interest – to reject the parties’ joint submission in the circumstances. 

The panel decided that the joint submission would not go against the public interest and would achieve the pertinent penalty goals. 

The panel held that the registrant engaged in professional misconduct under s. 51(1)(c) of the Health Professions Procedural Code, Schedule 2 to Ontario’s Regulated Health Professions Act, 1991. 

Regarding s. 51(1)(c), the panel found that the registrant breached the following paragraphs of s. 1 of Ontario Regulation 317/12, made under Ontario’s Psychotherapy Act, 2007: 

• paragraph 1: contravening a professional standard of practice or failing to maintain a professional standard of practice, including general conduct (1.5), conflict of interest (1.6), dual and multiple relationships (1.7), and consent (3.2) 
• paragraph 16: acting in a professional capacity while in a conflict of interest 
• paragraph 52: engaging in disgraceful, dishonourable, or unprofessional conduct 

The panel determined that the registrant committed the alleged professional misconduct and failed to obtain valid, prior, informed, and written consents to treatment.