SA psychologist Samantha Angelakis’ appeal dismissed after deliberately misleading the Psychology Board about relationship with client

A “goody-two-shoes” psychologist had her appeal dismissed after she said her shame over dating a client caused her to deceive the Psychology Board about the relationship timeframe.

A female psychologist who married a police officer client had her appeal dismissed after she claimed she didn’t intentionally deceive the Psychology Board about when their relationship started.

Dr Samantha Angelakis was found to have fallen substantially below the professional standard by a tribunal, including deliberately misleading the Board to make it appear nothing occurred during the treatment period.
Her counsel argued multiple grounds during an appeal hearing in September, including that Dr Angelakis’ shame over the ethical breach, as well as not having access to the emails sent, caused her to disremember specific timeframes of the relationship. They did not challenge the findings of her other unprofessional conduct.
However, Justice Ben Doyle said on his assessment of the evidence and logic of events Dr Angelakis must have appreciated or at least been reckless that what she said in her self-notification and first interview were inaccurate or misleading.

The tribunal findings

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.

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.

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

Dr Samantha Angelakis. Photo: PsychMed

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

Dr Angelakis and Insp. Arthur – who apparently separated from their respective married spouses on July 19, 2019 and later divorced– 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.

In her letter, Dr Angelakis said it was never her intention to commence a relationship within that timeframe, however the connection developed quicker “than we could have anticipated”.

“We believe there to be no power imbalance or exploitation on my part ... I do not pose an ongoing risk to the public, and am a conscientious, caring practitioner,” she said.

The court heard Dr Angelakis was “terrified” before her first interview with Ahpra after the self-notification stating: “I typically follow the rules … I’ve probably been guilty of being a goody-two-shoes, this is the worst thing I’ve done in my life, and I was really scared to go in there”.

“I remember feeling nauseous and as if I was going to throw up”.

Judgment on appeal

In Justice Doyle’s published judgment, he said he allowed for the possibility that Dr Angelakis’ shame and fear of the consequences may have made it difficult to revisit the details.

“But it is very difficult to think that (Dr Angelakis) did not remember the key elements of what was a momentous 24 hours which involved their final treatment session being followed by both of their existing marital relationships striking serious, if not terminal, difficulty, followed by the making of arrangements to meet at a private location the following night when they drank together and, ultimately, kissed,” he said.

Justice Doyle, dismissing the appeal, said this was not to say that there may not be significant reasons to be sympathetic towards Dr Angelakis’ position.

“Ethical obligations are uncompromising, but life is complicated,” he said.

“Nothing could be clearer than that the connection formed between (Dr Angelakis and Insp. Arthur) was powerful and mutually felt.”

Dr Angelakis will learn her penalty at a later date.

Originally published as SA psychologist Samantha Angelakis’ appeal dismissed after deliberately misleading the Psychology Board about relationship with client