Louisiana Psychologist Christopher D. Garner Suspended for Sex with Patient

December 16, 2018

On December 14, 2018, the Louisiana State Board of Examiners of Psychologists suspended the license of psychologist Christopher D. Garner.

According to the Board’s report, Garner was suspended on the basis of having violated numerous statutes and ethical standards by engaging in sex with a patient, including:

• Practicing psychology in such a manner as to endanger the welfare of clients or patients, including but not limited to engaging in sexual intercourse or other sexual contact with a client or patient. (Louisiana Revised Statutes § 37:2359 B.2.b)

• Gross malpractice, repeated malpractice, or gross negligence in the practice of psychology. (Louisiana Revised Statutes § 37:2359 B.2.c)

• Exercising undue influence in such a manner as to exploit the client or patient for financial or other personal advantage to the practitioner or a third party. (Louisiana Revised Statutes § 37:2359 B.8)

• Violation of the code of ethics adopted in the rules and regulations of the Board, or other immoral, unprofessional, or dishonorable conduct as defined in the rules and regulations of the board. (Louisiana Revised Statutes § 37:2359 B.12)

• Inability to practice psychology with reasonable skill and safety to patients or clients by reason of illness, inebriation, misuse of drugs, narcotics, alcohol, chemicals, or any other substance, or as a result of any mental or physical condition. (Louisiana Revised Statutes § 37:2359 B.13)

• Sexual harassment: solicitation, physical advances, or verbal or nonverbal conduct that is sexual in nature, that occurs in connection with the psychologist's activities or roles as a psychologist and that either unwelcome, is offensive, or creates a hostile workplace or educational environment, and the psychologist knows or is told this; or is sufficiently severe or intense to be abusive to a reasonable person in the context. (Louisiana Administrative Code, Title 46, Professional and Occupational Standards [specific to psychologists] §1307.B.1 and B.2)

• Avoiding Harm: failure to take reasonable steps to avoid harming clients/patients and to minimize harm where it is foreseeable and unavoidable. (Louisiana Administrative Code, Title 46, Professional and Occupational Standards [specific to psychologists] §1307.D)

• Engaging in multiple relationships with patients (by being in a professional capacity as the patient’s therapist and also functioning in a different capacity [such as social or business] with the same patient or is in a relationship with someone closely related to the patient, or promises to enter into another relationship in the future with the patient or the person close to the patient. (Louisiana Administrative Code, Title 46, Professional and Occupational Standards [specific to psychologists] §1307.E.1.a, b, c)

• Engaging in sexual intimacies with former patients for at least two years after the termination of therapy. The standard states that this does not occur “except in the most unusual circumstances” and that in even such cases, the psychologist still bears the burden of showing that they have not exploited the former patient.

Source: Disciplinary Action Report 7/1/18 - 6/30/19, Louisiana State Board of Examiners of Psychologists.