SA psychologist Samantha Angelakis denies misleading the Psychology Board after marrying police officer client

A psychologist who started dating a police officer she was treating for PTSD said she didn’t intend to deceive the Psychology Board about when their relationship started.

Dr Samantha Angelakis. Photos: PsychMed

A female psychologist who started dating a police officer client claimed she didn’t intend to deceive the Psychology Board about when their relationship started.

Dr Samantha Angelakis, 36, was found to have fallen substantially below the professional standard by a tribunal after she eventually married the client.

However, her counsel argued during an appeal hearing that Dr Angelakis’ state of mind at the time of her self-notification about the relationship should have been assessed subjectively.

In a decision published online in July, the South Australian Civil and Administrative Tribunal (SACAT) found Dr Angelakis engaged in unprofessional conduct on four grounds.

The tribunal heard Dr Angelakis was practising as a clinical psychologist at PsychMed and specialising in the clinical treatment of trauma recovery through cognitive behaviour therapy.

Dr Samantha Angelakis.

Craig Arthur, an Inspector with the South Australia Police, was referred to Dr Angelakis in 2019 in respect to work-related post traumatic stress disorder.

Insp. Arthur underwent clinical treatment with Dr Angelakis from April 17 to July 19, 2019.

The tribunal found there was a blurring of professional boundaries from June 11, 2019 and a noticeable shift in the nature and tone of the email exchanges, particularly from July 8, 2019.

Dr Angelakis admitted that between July 8-19, 2019 she attended exercise classes with Insp. Arthur and had takeaway coffee with him.

On July 19, 2019, which was the last day of treatment, Insp. Arthur sent Dr Angelakis an email saying he was tempted to send her a photo of himself in uniform.

The tribunal heard she replied: “PLEASE PLEASE PLEASE send the photo!!!! … Can’t wait to see you in uniform! Bet you drive the ladies mad”.

It was accepted by the parties that Dr Angelakis and Insp. Arthur then met on July 20, 2019 where they spent several hours holding each other and kissing.

It was also accepted that they had sexual intercourse for the first time six days later.

Dr Angelakis and Insp. Arthur – who apparently separated from their respective married spouses on July 19, 2019 – ended up marrying in January 2021.

She made a self-notification to the Board of Australia on February 7, 2020 who referred her to the Tribunal.

Clause C. 4.3 of the Code stipulates psychologists must not engage in sexual activity with a former client within two years after terminating their professional relationship.

The tribunal found Dr Angelakis also behaved in a way that constituted professional misconduct by deliberately misleading the Board to make it appear nothing occurred during the treatment period.
In an appeal hearing before Justice Ben Doyle, counsel for Dr Angelakis told the court they had issue with the tribunal’s findings that their client deliberately or recklessly misled the Board in her self-notification and first interview with Ahpra.
Counsel said the tribunal undertook an objective assessment of Dr Angelakis’ state of mind when it should have been a subjective assessment and she had no intention to deceive the Board.

They said Dr Angelakis didn’t have access to the emails sent between herself and Insp. Arthur at the time of the self-notification so she didn’t appreciate the significance of her perception in July 2019 about how fast her feelings developed.

“The tribunal failed to engage with her evidence about a lack of recollection in the absence of the emails,” counsel said.

Counsel, for the Psychology Board, told the court the code made it clear that the relationship a psychologist is expected to have with their client is a therapeutic one only.

“Of course the board is proceeding on objective evidence, given the documents,” they said.

The decision has been reserved.