Board Suspends Psychologist James E. Gebhart for Sexual Relationship with Patient

December 11, 1992

On December 10, 1992, the Ohio State Board of Psychology suspended the license of psychologist James E. Gebhart for 60 days based on allegations that he engaged in a sexual relationship with a female patient he treated from 1980 to 1985. 

The Board's Notice of Opportunity for Hearing contained the following information: 

"During a time period beginning about October, 1979 until about June 16, 1984 (date of licensure) you were under the supervision of Rahe Corliss, Ph.D. for Psychological work performed and supervised training/experience toward licensure. While functioning as Dr. Corliss’ supervisee, Client "K" consulted you for psychological services about April of 1980. Client "K" continued to receive treatment from you (both individual and group) from April, 1980 until approximately October 14, 1985. Throughout the years client "K" was treated by you, you engaged in inappropriate behavior of a sexual nature.

"Specifically, there were numerous instances of hugging, kissing and fondling. Some sessions were conducted, wholly or in part, while reclining on the sofa, sitting on the floor together or in a recliner.

"You engaged in fondling of Client "K’s” body, which you termed to be "bioenergetic" exercises/therapy, including massaging her stomach beneath her clothing.

"Client "K" was required to suck on the corner of a pillow, pretending it was a penis, and to sit on your lap for rebirthing.

"On several occasions you positioned Client "K" on top of you and forced her to engage in pelvic thrusting against your thigh and genitals. On other occasions you lay on top of her, rubbing your genitals against hers; terming these actions "dancing" together.

"On one or more occasions, you inserted your fingers into Client "K’s” mouth, while insisting that she suck upon them and pretend them to be your penis;

"You engaged in mutual manipulation of genitals with Client "K", using your fingers or a vibrator to manipulate her to orgasm, and requiring her to manipulate you to orgasm, while demanding that she utter obscenities to you.

"On one occasion, you required Client "K" to perform oral sex upon you.

"You encouraged Client "K” to pen both love letters and sexual fantasies involving you and accepted gifts from her.

"You requested (and received) from Client "K" audio tapes of a sexually suggestive nature, in which she would engage in sexual activity while speaking your name and verbalizing her emotions and feelings for you.

"Further, you requested (and received) one or more nude photographs of Client "K.”

"Further, in view of the outcome of the treatment and the lack of progress in Client "K’s” case, which extended over a five-year period, you failed to adequately handle transference issues as weIl as the techniques related to physical contact. You encouraged inappropriate expression of anger, inappropriate expression of sexuality, and engaged in inappropriate physical contact with the client. The techniques of hugging and conducting therapy while sitting on the floor together appear to have only intensified the transference process rather than deleting it or using it in a productive way toward the growth of the client. You should have distanced yourself from a client exhibiting the dynamics that Client "K" was exhibiting, rather than trying to get closer to her.

"Your actions reveal a lack of competence and a lack of sound judgment and fail to meet acceptable standards of professional practice.

Source: Consent Agreement Between James E. Gebhart, Ph.D. and the Ohio State Board of Psychology, December 10, 1992.