Psychiatric Malpractice: Exploitation of Women Patients
![handle is hein.journals/hwlj11 and id is 91 raw text is: PSYCHIATRIC MALPRACTICE: EXPLOITATION OF
WOMEN PATIENTS
DENISE LEBOEUF*
INTRODUCTION
In New York a psychiatrist promised his patient he could
cure her lesbianism if she would have sex with him.1
A patient in California was told by her psychiatrist that she
faced a ninety-day involuntary commitment to a mental hospital
if she refused to have sex with him.2
An army therapist, having told his patient she needed an
affair, threatened to terminate therapy if she would not continue
their sexual relationship.3
A San Diego woman lost custody of her two children as a result
of a sexual affair with her psychiatrist.4
A former patient requested after-care counselling from her psy-
chiatrist of thirteen years: instead, he beat her and assaulted her
sexually. She was admitted to a psychiatric hospital.5
A psychiatrist attending a woman hospitalized for depression
convinced her to have sexual relations with him; she subse-
quently killed herself.6
* Student, Tulane Law School. The author is indebted to Professor Ruth Colker, whose
teachings and writings on the legal concerns of women inspire her students, and whose
encouragement and suggestions made this article possible. Responsibility for the ideas
expressed is of course assumed by the author. Gratitude is also owed to Marie Mire, for
her insight and research assistance, and particularly to Rosemary LeBoeuf for her word
processing skills, editorial assistance, and abundant emotional support.
IRoy v. Hartogs, 81 Misc. 2d 350, 351, 366 N.Y.S.2d 297, 298 (1975); Hartogs v.
Employers Mut. Ins. Co., 89 Misc. 2d 468, 469, 391 N.Y.S.2d 962, 963 (1977) [hereinafter
Employers Mut.].
2 Waters v. Bourhis, 142 Cal. App. 3d 235, 237-38, 190 Cal. Rptr. 833, 835 (1983) (en
bane).
3 Andrews v. United States, 732 F.2d 366, 368-69 (4th Cir. 1984).
4 Walker v. Parzen, 24 ATLA L. Rep. 295 (San Diego Super. Ct., July 7, 1981).
5 Dennis v. Allison, 678 S.W.2d 511 (Tex. Civ. App. 1984), aff'd, 698 S.W.2d 94 (1985).
6 Anclote Manor Found. v. Wilkinson, 263 So. 2d 256 (Fla. 1972).](ViewImageLocal?handle=hein.journals/hwlj11&div=8&collection=&method=preview&ext=.png&size=3)
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Psychiatric Malpractice: Exploitation of Women Patients
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