Psychotherapy Articles

Psychotherapy Articles

Sexual Harassment In Supervision

It's Not Just Unethical…It's Illegal

Internet Editor’s Note: Dr. Friedlander recently published an article titled “Use of relational strategies to repair alliance ruptures: How responsive supervisors train responsive psychotherapists” in Psychotherapy.

If you’re a member of the Society for the Advancement of Psychotherapy you can access the Psychotherapy article via your APA member page.

Not a member? Purchase the Psychotherapy article for $11.95 here.

Or, Join the Society for $40 a year and receive access to more than 50 years of articles.

We’re taking this opportunity to raise an issue that’s sorely neglected in our professional dialogue, namely sexual harassment in the context of psychotherapy supervision. As far as we could discover, the topic of “sexual intimacies” (Bartell & Rubin, 1990) or “sexual boundary violations” (Koenig & Spano, 2004) did not appear in the supervision literature until 1979 (Pope, Levenson, & Schover, 1979), at a time when concern about sexual relations between professors and students was a hot topic in higher education.

In the past 15 years or so, some psychology trainees’ experience of unwanted sexual attention or “advances” have been documented in the context of research findings on what has come to be called harmful supervision (e.g., Ellis et al., 2014; Gray, Ladany, Walker, & Ancis, 2001; Nelson & Friedlander, 2001; Walker, Pate-Carolan, & Ladany, 2007). While sexual relationships between trainees and supervisors tend not to occur often (Ellis, 2001; Ellis et al., 2014), these relationships can clearly be damaging. However, almost all of the available literature focuses on the emotional consequences of romantic relationships between supervisors and supervisees, assuming perhaps that they are consensual, with little discussion of the illegality of unwanted sexual attention.

Psychologists have long been aware that engaging in a sexual relationship with a client causes harm even when the client is the one to initiate the relationship. For this reason, many of us believe that despite the ethical guideline to refrain from acting on one’s romantic interest in a client for a period of two years, such relations should never occur.

Whereas the potential for harm to a client is readily apparent, in the context of clinical supervision it is easy to overlook. After all, the supervisee’s mental health is not the focus of attention, and presumably both parties – colleagues who often socialize with one another at work and outside of work — can be considered “consenting adults.” However, in supervision, just like in psychotherapy, what may begin as a “consensual” relationship may eventually be viewed as exploitative.

And…are students in training really free to “consent,” given the power hierarchy and explicitly evaluative, nonvoluntary, gatekeeping nature of clinical supervision? Apparently the authors of APA’s ethics code thought not. The code explicitly prohibits “sexual relationships” (http://www. code/principles.pdf, retrieved 8/13/15; Standard 7.05, p. 10) between students and supervisees and admonishes psychologists to avoid “exploitation or harm” in “multiple relationships” (Standard 3.05, p. 6). Reflecting this prohibition, in their classic text on supervision Bernard and Goodyear (2014) point out that, “…expecting or requesting sexual favors or taking sexual liberties with their supervisees is a clear abuse of the power afforded supervisors by virtue of their professional status, is unethical, and falls into the category [of] the predatory professional” (p. 203).

These and other authors (e.g., Brodsky, 1980) clearly recognized that the harm caused by a sexual relationship with a supervisor does not only affect the supervisee, since the concomitant stress and loss of objectivity are likely to compromise client welfare. It is not difficult to imagine how the impaired judgment and complex dynamic brought about by a sexual relationship could “trickle down” so as to jeopardize the quality of care provided to clients. For instance, a supervisor’s feelings could well lead him/her to avoid meaningfully challenging a supervisee’s work with clients in order to avoid upsetting their romantic relationship. Or, a supervisee’s desire for the supervisor’s unconditional approval and/or fear of losing their relationship could result in nondisclosure of important clinical material, such as an alliance rupture, countertransference, and – particularly – feelings of sexual attraction toward a client.

But our point is not solely about actual sexual relationships. What we want to draw your attention to is how supervision conversations that may seem pertinent and meaningful to a supervisor can feel erotic, unwelcome, and offensive to a supervisee.

Simply put, a supervisor may not view his/her remarks to a supervisee to be inappropriate or unethical — when in fact they are illegal. What takes place in clinical supervision that does not rise to the level of a romantic or sexual “relationship,” or even a “sexual advance,” may nonetheless be experienced by a supervisee as exploitative, harmful, and traumatic – a.k.a. harassment.

By definition, sexual harassment refers to unwelcome sexual attention in the workplace, including offensive comments about an employee’s sex or about women or men in general. Legally, harassment is defined as occurring when the unwelcome sexual attention is “so frequent or severe that it creates a hostile or offensive work environment or when it results in an adverse employment decision” ( sexual_harassment.cfm, retrieved 8/13/15). In APA’s Code of Ethics (Standard 3.02) , sexual harassment is defined as, “…sexual 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 (1) is unwelcome, is offensive, or creates a hostile workplace or educational environment, and the psychologist knows or is told this or (2) is sufficiently severe or intense to be abusive to a reasonable person in the context. Sexual harassment can consist of a single intense or severe act or of multiple persistent or pervasive acts.” (Note that by this definition, even when a licensed therapist is paying for supervision with personal funds, an unwelcome sexual advance occurring “in connection with the psychologist’s activities or roles as a psychologist” constitutes harassment.)

Unlike psychotherapy, supervision is a work relationship. For students in training, supervision is not voluntary. It is explicitly evaluative. Indeed, the hierarchical structure and the power dynamic in supervision, long a topic of scholarship in the literature on gender in supervision (e.g., Barnes & Bernard, 2003), make women and minority group members particularly vulnerable to harassment. Psychology interns and post-docs are also vulnerable because they tend to be distant from their academic programs and training directors.

Lodging a complaint about a supervisor’s unwelcome sexual comments can result in a poor clinical evaluation. Students are all too aware of this possibility. They tend to suffer in silence (Ellis, 2001; Nelson & Friedlander, 2001), petrified that naming the beast can end their careers.

Why do we bring this concern to you now? For three reasons: First, the supervision relationship is prominently emphasized in the current literature. Authors have written about how to handle sexual attraction and role conflict between supervisor and supervisee (e.g., Ladany, Friedlander, & Nelson, 2005), about supervisees’ nondisclosure of negative perceptions and feelings about their supervisors (Ladany, Hill, Corbett, & Nutt, 1996; Nelson & Friedlander, 2001), and about the damaging effects of ruptures in the supervisory alliance (e.g., Friedlander, 2015; Safran, Muran, Stevens, & Rothman, 2008; Watkins & Hook, 2015). Effective supervision often involves highly personal material. Moreover, conversations about what is occurring “in the here-and-now” are generally welcome and helpful in supervision (just as they are in psychotherapy) — especially when countertransference and parallel processes are evident. However, intimate dialogue has the potential for sexualizing the supervision relationship.

Second, we noticed that the recently published Guidelines for Clinical Supervision (APA, 2015), written by eminent scholars in the field, while explicit about the need for supervisors to follow APA’s ethics code, is curiously silent about sexual harassment, a term that we tend not to think about in education, as it is more often associated with work settings. Yet clinical supervision is a work activity in a work setting, and when a supervisee receives a negative evaluation from a supervisor after making a formal complaint about his/her behavior, this is “an adverse employment decision.”

Third, the Hoffman report, and all that it represents for our profession, demonstrates the slippery slope of ethical transgressions, a point that right now we are – and should be – acutely aware of. We should be making this point with graduate students in our academic programs and with trainees in our clinical settings.

In the remainder of this piece, we discuss how erotic conversations – harassing conversations – can take place in supervision. To frame this discussion, we quote from Anonymous (1991), a female doctoral student who wrote a disturbing personal account about how the romantic advances of her supervisor, welcome at first, became harassment:

…[my client’s] case had recently taken a complicated turn, and I felt that I was in over my head. I made an early morning appointment to see Professor X for supervision.

We watched the videotape of my last session with the client, and Professor X gave me the guidance I needed. He then turned his attention directly to me. Facing me squarely and looking intently into my eyes, he pointed out that based on recent observations he was troubled by my tendency to nurture clients. Could this be symptomatic of a problem in my own life? He wondered if I had needs that weren’t being met. This unexpected personal attention caught me off guard. I started to reflect upon my needs, gradually focusing all my thoughts inward. I had such a difficult time for so long. I was tired of the constant intellectual, physical, and emotional demands. All of the emotion I had been feeling recently began to surface, and I started to cry. He was immediately empathic. He spoke softly, consoling me and handing me a tissue to wipe away my tears.

He then cocked his head to one side, smiled knowingly, and asked, “Could I give you a hug without your thinking I’m coming on to you?” What a relief! He openly acknowledged that he knew that I had interpreted his previous actions as a sexual advance, and with these words he guaranteed that he would not let that happen now. I let him take me into his arms and his hug felt comforting. “You know I felt scared before,” I admitted.

After a few moments, I was ready for the embrace to end. But he continued to hold me closely with no release….

Rather than let me go, he began a slow series of soft nuzzling kisses over my head and back and forth from one side of my head to another. I was puzzled by these kisses at first and then irritated at myself. Why had I agreed to this without knowing what he meant by a hug? (p. 503).

While this example is blatantly sexual harassment, harassment can and does arise in a much more subtle fashion when the supervision talk, perhaps legitimate on one level, winds up feeling like “unwanted sexual attention” to the supervisee. We encourage you to read the entire Anonymous (1991) article to see the subtle ways in which the author’s supervisor made her feel vulnerable, and how feelings of closeness in their supervision relationship were gradually transformed into exploitation.

This case also shows how the power differential and internalized gender attitudes contributed to this supervisee’s self-blame and confusion. Further, the case highlights the predicament a supervisee can find herself (or himself!) in when weighing how to respond to a supervisor’s boundary violation. If a supervisee doesn’t reject the sexual advances in the moment, s/he may wind up viewing herself (and be seen) as “asking for it.” Conversely, if s/he forcefully rejects the supervisor’s advances, she renders herself vulnerable to his anger and embarrassment over being rejected.

Unlike clients, supervisees cannot “drop out” of supervision. In the context of harassment, a supervisee becomes paralyzed and isolated from her/his peers — effectively silenced.

As in Anonymous’s (1991) case, discussions of highly personal material, transference reactions, and examinations of what is occurring in the here-and-now are intended to facilitate supervisees’ work with clients and development of self-awareness. However, the often revealing, sensitive, and emotionally charged nature of these immediacy conversations, occurring as they do in an evaluative context, can make a supervisee feel exposed, unsafe and powerless. Process-oriented discussions may be how a supervisor conveys sexual feelings to a supervisee indirectly, under the guise of trying to understand the supervisee’s relationship with a client (e.g., “It’s clear he finds you tremendously attractive”). This circuitous disclosure of the supervisor’s own romantic interest in the supervisee may be a not-so-subtle way of “testing” the supervisee’s receptivity to boundary crossing.

Unfortunately, conversations on cultural issues — particularly when they have to do with physical appearance — are yet another way that some supervisees wind up feeling objectified and marginalized. Indeed, a supervisor’s seemingly helpful comments about gender and racial differences may be experienced as unwanted sexual attention. Consider, for instance, a male supervisor who invites his supervisee to consider how “you being a young, buxom, appealing Latina is affecting how this flat-chested, unattractive female sees you, even though she’s White.” Even if this is an astute observation about how the client may be viewing the supervisee, the supervisor’s objectifying and culturally insensitive comment conveys that he finds the supervisee to be physically appealing, perhaps even sexually arousing.

A frank discussion of sexual harassment calls for a candid and unflinching consideration of how patriarchy, sexism, and cultural discourse play out in a supervisory context, as in any other work context. We do not mean to imply that supervisory relationships are inherently or even commonly experienced as sexual or erotic, but rather to acknowledge that deeply embedded cultural scripts regarding gender, sexuality, and power are far from absent in supervisory relationships. It seems important for supervisors to recognize the ways in which they benefit from having the attention of traditionally young, admiring supervisees who are dependent on them, given the all-too-human desire to subtly reinforce one’s position of influence.

In an ideal world, supervisees should feel empowered to lodge a harassment complaint when they are disturbed by unwanted sexual attention. However, due to the power differential in supervision and the explicitly evaluative nature of clinical training, many supervisees remain silenced, fearing retaliation.

So What Are a Supervisee’s Options?

Simply put, lodging a complaint of harassment takes immense personal courage and can result in significant financial, emotional, and/or professional costs.

The first course of action should be to lodge a formal complaint with other faculty in the graduate program and/or with the university’s office of judicial affairs or conflict resolution. A university investigation may not be possible, however, if the supervisor does not work for the university but is on staff at an external agency. On the other hand, faculty in APA-accredited academic programs and internships need to report all formal complaints to the Commission on Accreditation (CoA) when the program is being re-accredited, and students can lodge a formal complaint against an accredited program with the CoA at any time.

Here is what happened with Anonymous (1991):

I met with the OEO director and an associate provost and gave my statement.

Professor X was notified and an investigation began. Within a few days I learned his response: He denied my allegations. He emphasized that I had been under a lot of stress and was therefore likely to misinterpret his actions. He persuaded the student who was his lover to write a letter to his dean denying what she had told me [that he “talked about me constantly”], and he claimed that my advisor and I had teamed up to “entrap him.” Unofficially he promoted the idea that I was not attractive enough to sexually harass. (p. 505).

There are three other options for supervisees, beyond a grievance at the university level:

Option 1: If a supervisee is willing to navigate the daunting and often demeaning court system, litigation is possible. If a supervisor’s behavior meets the state specific or federal definition of sexual harassment, and if the local district attorney is willing to prosecute, a supervisor may receive a felony conviction and possible imprisonment.

Option 2: A second, albeit costly, alternative is a civil lawsuit. Although the standard of proof is not as stringent in civil suits, this option requires finding an attorney who is willing to accept the case on commission.

Option 3: A third, potentially less traumatic option is for the supervisee to file a complaint with the state licensing board. Potential outcomes for the supervisor could be a fine, suspension of the supervisor’s license pending remediation, or the loss of the license altogether.

Whether or not one of these courses of action is followed, if the supervisor is a member of APA the supervisee can submit a formal complaint of unethical conduct to the Ethics Committee. In order for the complaint to be processed, the supervisee is required to (1) grant permission to the supervisor to release any confidential information regarding the supervisee and associated interactions (2) grant the Ethics Committee permission to provide the supervisor with any materials submitted by or on behalf of the trainee, and (3) waive any right to subpoena from the APA for the purposes of private civil litigation. However, since APA is a voluntary membership organization, this Committee’s strongest sanction is disbarment from the association.


Although Anonymous’s (1991) supervisor was formally reprimanded by the university, she continued to be plagued with emotional distress. Eventually, she decided to lodge a formal complaint with two professional counseling associations. He resigned from one association before being investigated, and the other one put him on probation. Here is how she described her experience:

Each time I communicated with my mentor about my writing [the Anonymous article] or with a counseling official about my ethics complaints, I felt the weight of the harassment lift a little more. My concerns were taken seriously and addressed efficiently, and I was always treated with kindness and respect. In addition to easing my pain, my interactions with these counseling professionals allowed me to restore my faith in and respect for the profession…. (p. 506)

Anonymous’s (1991) experience happened more than 25 years ago. We wrote this piece because, unfortunately, sexual harassment in supervision continues to this day.

Cite This Article

Friedlander, M. L., & Dubovi, A. (2015, November). Sexual harassment in supervision: It’s not just unethical…it’s illegal. [Web article]. Retrieved from:


Anonymous. (1991). Sexual harassment: A female counseling student experience. Journal of Counseling and Development, 69, 502-506.

American Psychological Association (2015). Guidelines for clinical supervision in health service psychology. American Psychologist, 70, 33-46.

Barnes, K. L., & Bernard, J.L. (2003). Women in counseling and psychotherapy supervision. In M. Kopala & M. A. Keitel (Eds.), Handbook of counseling women. (pp. 535-545). Thousand Oaks, CA: Sage.

Bartell, P. A., & Rubin, L. J. (1990). Dangerous liaisons: Sexual intimacies in supervision. Professional Psychology: Research and Practice, 21, 442-450.

Bernard, J. M., & Goodyear, R. K. (2014). Fundamentals of clinical supervision (5th ed.). Boston, MA: Pearson.

Brodsky, A. M. (1980). Sex role issues in the supervision of therapy. In A. K. Hess (Ed.), Psychotherapy supervision: Theory, research and practice. (pp. 509-522). New York: Wiley.

Ellis, M.V. (2001). Harmful supervision, a cause for alarm: Comment on Gray et al. (2001) and Nelson and Friedlander (2001). Journal of Counseling Psychology, 48, 401-406.

Ellis, M. V., Berger, L., Hanus, A., Alaya, E. E., Siembor, M. J., & Swords, B. A. (2014). Inadequate and harmful clinical supervision: Revising the framework and assessing occurrence. The Counseling Psychologist, 42, 434 – 472.

Friedlander, M. L.  (2015). Use of relational strategies to repair alliance ruptures:  How responsive supervisors train responsive therapists.  Psychotherapy, 52, 174-179.

Gray, L. A., Ladany, N., Walker, J. A., & Ancis, J. R. (2001). Psychotherapy trainees’ experience of counterproductive events in supervision. Journal of Counseling Psychology, 48, 371-383.

Koenig, T. L., & Spano, R. N. (2004). Sex, supervision and boundary violations. The Clinical Supervisor, 22, 3-19.

Ladany, N., Hill, C. E., Corbett, M. M., & Nutt, E. A. (1996). Nature, extent, and importance of what psychotherapy trainees do not disclose to their supervisors. Journal of Counseling Psychology, 43, 10-24.

Larrabee, M. J., & Miller, G. M. (1993). An examination of sexual intimacy in supervision. The Clinical Supervisor, 11, 103-126.

Nelson, M. L., & Friedlander, M. L. (2001). A close look at conflictual supervisory relationships: The trainee’s perspective. Journal of Counseling Psychology, 48, 384-395.

Pope, K. S., Levenson, H., & Schover, L. (1979). Sexual intimacy in psychology training: Results and implications of a national survey. American Psychologist, 34, 682-689.

Safran, J. D., Muran, J. C., Stevens, C., & Rothman, M. (2008). A relational approach to supervision: Addressing ruptures in alliance. In C. A. Falender & E. P. Shafranske (Eds.), Casebook for clinical supervision: A competency-based approach (pp. 137–157). Washington, DC: American Psychological Association.

Walker, J. A., Ladany, N., & Pate-Carolan, L. M. (2007).  Gender-related events in psychotherapy supervision: Female trainee perspectives.  Counselling and Psychotherapy Research, 7, 12-18.

Watkins, Jr., C. E., Spano, S. H., Ramos, M. J., & Hook, J. N. (2015). The ruptured supervisory alliance and its repair: On supervisory apology as a reparative intervention. The Clinical Supervisor, 34, 98-114.


Submit a Comment

Your email address will not be published. Required fields are marked *