Consultation on Cross-Examining Mental Health Testimony

I provided consultation to a client-parent and client-attorney regarding the cross-examination of mental health testimony. I thought you might find this information helpful so I’m posting it to my blog.

The Context:

I’m am providing consultation to an attorney-client and their parent-client regarding  two “expert” forensic custody evaluations by two different psychologists, one better and one worse. The client-attorney and their client-parent want to support and expand on the report and recommendations of the better doctor, Dr. Better-doctor, and discredit the report and recommendations of the bad doctor, Dr. Bad-doctor.

I read all the reports and we met in my online office where I provided feedback on the two reports. We talked about areas of opportunity and vulnerability. Afterwards, I was asked a question in email,

Q: Is a cross-generational coalition considered child psychological abuse?

I provided an email answer to the question. I thought my answer to my client-attorney might also be helpful to you – so here’s my consultation answer to a client-attorney and their client-parent to the question they asked within the context of two mental health reports, one better one worse, both from forensic psychologists.

Dr Childress Answer:

No, a cross-generational coalition is not automatically child abuse – although – the criteria for psychological child abuse are sufficiently vague that a licensed mental health professional can give the diagnosis based on their judgment – so yes, maybe. If the licensed MH person says it’s child abuse, it’s child abuse.

If they don’t give the diagnosis of child psychological abuse for a cross-generational coalition, however, we can’t overrule them, it’s a judgment call… unless it’s a persecutory delusion or Factitious Disorder Imposed on Another, both of those diagnosis would clearly also be child psychological abuse.

Abuse Diagnoses

The diagnosis that’s relevant for the child’s ongoing protection is Child Psychological Abuse (V995.51). The Child Psychological Abuse diagnosis is based on either of two diagnoses, 1) a shared (induced) persecutory delusion in the child, or 2) a false (factitious; artificially created) attachment pathology imposed on the child by the father, a Factitious Disorder Imposed on Another.

These diagnoses of a shared (induced) persecutory delusion and FDIA are technical diagnoses that will need to be made by a mental health professional. The judge will likely be reluctant to identify the problem (diagnose the pathology) as a shared (induced) persecutory delusion with the child and as a false (factitious) attachment pathology being imposed on the child by the father’s distorted parenting.

The Problem

The problem is that you’ve had two mental health evaluations, one by Dr. Better-doctor and one by Dr. Bad-doctor, and neither of them addressed the issues of abuse. There are two abuse diagnoses relevant for consideration, Spousal Psychological Abuse (V995.82) using the child as the weapon, and Child Psychological Abuse (V995.51) that involves creating a shared (induced) persecutory delusion and factitious (artificially created) attachment pathology in the child by the father to manipulate the court’s decisions regarding child custody, and to meet the father’s own emotional and psychological needs… and neither of them even assessed for the possibility.

The ONLY reason I am involved is because both Dr. Better-doctor and Dr. Bad-doctor are ignorant, incompetent, negligent and unethical, and they both failed to in their duty to protect obligations on two separate counts, 1) failure to protect the child from child abuse, and 2) failure to protect the mother from spousal abuse by the father using the child as the weapon.

Ignorant

Google ignorant: lack of knowledge or information

• • They lack knowledge about delusional disorders, factitious disorders, cross-generational coalitions, and enmeshment, they applied no “established scientific and professional knowledge of the discipline” as the bases for their professional judgments – just a rejected and “controversial” construct of “parental alienation” about which even Better-doctor and Bad-doctor can’t agree.

• • Based on a review of their reports, Drs. Better-doctor and Bad-doctor are ignorant by definition of the English language, and they don’t care.

Incompetent

Google incompetence: inability to do something successfully

• • Even AFTER their assessments taking months and months of time to complete, they STILL failed to conduct a proper risk assessment for any of the potential abuse diagnoses – we still don’t have an answer to the central question they were asked – what is the pathology? – what is the problem? – using the application of professional-level knowledge.

• • They were unable to successfully conduct an evaluation that accurately identified (diagnosed) the problem (pathology), and as a result of their incompetence (inability to do something successfully) you are now stuck in the trial situation trying to convince the judge there are abuse diagnoses and that a child protection response is warranted.

Negligent

Google negligence: failure to take proper care in doing something

• • Did Drs. Better-doctor and Bad-doctor fail to conduct a proper assessment for a possible delusional thought disorder – a Mental Status Exam of thought and perception?

• • Did Drs. Better-doctor and Bad-doctor fail to conduct a proper risk assessment for possible Child Psychological Abuse? Did they even consider the diagnosis? Did they consider any abuse diagnosis – or did they just miss the diagnosis  – misdiagnosis – did they misdiagnose child abuse because they were negligent in their evaluation?

• • Get Dr. Bad-doctor to admit at some point that he recommends an additional “risk assessment” for “possible” child psychological abuse and a “possible” persecutory delusion… then ask him where in his report he discussed these possibilities? If we STILL need ANOTHER assessment for possible child abuse even AFTER his assessment, then he was negligent in conducting his assessment – he failed to take proper care.

• • He should have known there was a possible persecutory delusion – that’s the Walters & Friedlander quotes in the flagship journal of the AFCC, Family Court Review – 2016, seven years ago – this isn’t new information. Why didn’t Dr. Bad-doctor consider a possible encapsulated persecutory delusion? He’s a prominent court-involved forensic psychologist – Family Court Review is their journal.

From Walters & Friedlander: “In some RRD families [resist-refuse dynamic], a parent’s underlying encapsulated delusion about the other parent is at the root of the intractability (cf. Johnston & Campbell, 1988, p. 53ff; Childress, 2013). An encapsulated delusion is a fixed, circumscribed belief that persists over time and is not altered by evidence of the inaccuracy of the belief.”

From Walters & Friedlander: “When alienation is the predominant factor in the RRD [resist-refuse dynamic}, the theme of the favored parent’s fixed delusion often is that the rejected parent is sexually, physically, and/or emotionally abusing the child. The child may come to share the parent’s encapsulated delusion and to regard the beliefs as his/her own (cf. Childress, 2013).” (Walters & Friedlander, 2016, p. 426)

Walters, M. G., & Friedlander, S. (2016). When a child rejects a parent: Working with the intractable resist/refuse dynamic. Family Court Review, 54(3), 424–445.

Unethical

They are unethical – APA ethics code. They have ethical obligations to know what they’re doing (Standard 2.01 Boundaries of Competence), they are not allowed to be ignorant and incompetent. They have ethical obligations to apply the “established scientific and professional knowledge of the discipline” as the bases for their professional judgments (Standard 2.04 Bases for Scientific and Professional Judgements).

2.04 Bases for Scientific and Professional Judgments
Psychologists’ work is based upon established scientific and professional knowledge of the discipline.

Ask them to explain why that’s important.

Q: Is the APA ethics code optional or mandatory? A: mandatory.

Q: Please read this ethical Standard. Do you agree with that Standard? Do you comply with that ethical Standard? Why is that Standard important, what bad things happen if that Standard is violated?

Standard 2.04:

Q: Why is it an ethical obligation to apply the “established scientific and professional knowledge of the discipline” as the bases for your professional judgments?

Q: What bad things can happen if you don’t apply the established knowledge as the bases for your professional judgments?

Standard 9.01

Standard 9.01 Bases for Assessment is the Standard we will land on to discredit Dr. Bad-doctor’s report and recommendations. Notice that Standard 9.01 cites specifically back to Standard 2.04 – ask them to explain why?

9.01 Bases for Assessments
(a) Psychologists base the opinions contained in their recommendations, reports, and diagnostic or evaluative statements, including forensic testimony, on information and techniques sufficient to substantiate their findings. (See also Standard 2.04, Bases for Scientific and Professional Judgments.)

Q: Is family systems therapy (Munchin, Bowen, Haley, Madanes, Satir) among the established scientific and professional knowledge of the discipline?

Q: Why would the constructs of family systems be important to apply in understanding family conflict?

Q: What is triangulation? If I say the child is being ‘triangulated’ into the spousal conflict, what does that mean?

Q: What is a cross-generational coalition? What is an emotional cutoff? What is enmeshment?

Q: Show me in your report where you applied the constructs of family systems as the bases for your professional judgments about this family conflict.

Q: Is the DSM-5 among the established scientific and professional knowledge of the discipline?

Q: What’s a persecutory delusion?

Q: Here’s the definition of a persecutory delusion from the American Psychiatric Association. Do you agree with that definition of a persecutory delusion?

From the APA: “Persecutory Type: delusions that the person, or someone to whom the person is close) is being malevolently treated in some way.” (American Psychiatric Association, 2000)

Q: Do you agree with that definition of a persecutory delusion from the American Psychiatric Association?

Q: Based on your assessment, do the father and child share a false belief that the child is “being malevolently treated in some way” by the mother?

Q: Read this quote from Walter’s and Friedlander from the journal Family Court Review, do you agree with their statement about child resistance of contact in family court litigation?

From Walters & Friedlander: “In some RRD families [resist-refuse dynamic], a parent’s underlying encapsulated delusion about the other parent is at the root of the intractability (cf. Johnston & Campbell, 1988, p. 53ff; Childress, 2013). An encapsulated delusion is a fixed, circumscribed belief that persists over time and is not altered by evidence of the inaccuracy of the belief.”

From Walters & Friedlander: “When alienation is the predominant factor in the RRD [resist-refuse dynamic}, the theme of the favored parent’s fixed delusion often is that the rejected parent is sexually, physically, and/or emotionally abusing the child. The child may come to share the parent’s encapsulated delusion and to regard the beliefs as his/her own (cf. Childress, 2013).” (Walters & Friedlander, 2016, p. 426)

Walters, M. G., & Friedlander, S. (2016). When a child rejects a parent: Working with the intractable resist/refuse dynamic. Family Court Review, 54(3), 424–445.

Q: Do you agree with those statements from Walters & Friedlander in the journal Family Court Review?

Q: Show me in your report where you discuss the possibility of a shared persecutory delusion of the father and child toward the mother?

Q: Did you even assess for a possible shared persecutory delusion – show me where?

Q: What is the assessment for a persecutory delusion? Is it a Mental Status Exam of thought and perception? Did you conduct a Mental Status Exam of thought and perception?

Q: The child and father have a false belief that the child is being malevolently treated in some way by the mother, could there possibly be a persecutory delusion with the father that’s being imposed on and induced in the child? Is that possible?

Q: Show us in your report where you assess for and discuss this possibility?

Q: Should we get an additional assessment for that possibility? Would you recommend we get an additional assessment to rule-out a possible persecutory delusion in the family?

If they say yes – then their opinions as contained in their recommendations, report, diagnostic or evaluative statements, including their forensic testimony, are NOT based on information (Standard 2.04) and techniques (MSE of thought and perception) sufficient to substantiate their findings – Standard 9.01 Bases for Assessment.

Because they don’t know the established knowledge (Standard 2.01) and didn’t apply the established knowledge (Standard 2.04), their opinions as contained in their recommendations, reports, diagnostic or evaluative statements, including their forensic testimony, are NOT based on information (Standard 2.04 violation) and techniques (Mental Status Exam of thought and perception) sufficient to substantiate their findings – a violation to Standard 9.01 Bases for Assessment – this is the Standard to land on with Dr. Bad-doctor to discredit his findings and recommendations.

You can rattle Dr. Better-doctor’s cage with the issue of 2.04, but then guide her back to the accurate information and allow her to embrace as much as she is comfortable with – “Hypothetically doctor….” – “Would what you describe there be consistent with…?” – “Based on what you said there, would you be worried about a possible…?”

Notice Standard 9.01 Bases for Assessment cites specifically back to Standard 2.04 Bases for Scientific and Professional Judgments – ask Dr. Bad-doctor why this is important,

Q: Why does Standard 9.01 Bases for Assessment specifically cite back to Standard 2.04? Why is it an ethical obligation to apply the “established scientific and professional knowledge of the discipline” in the interpretation of your assessment findings – Standard 9.01?

Q: What bad things could happen if a psychologist does NOT apply the “established scientific and professional knowledge of the discipline” in the interpretations of your assessment findings?”

Make him cut his own throat before he even starts.

To be clear, the problem is that Dr. Better-doctor and Dr. Bad-doctor are ignorant, incompetent, negligent, and unethical, and as a result they misdiagnosed child abuse and spousal abuse and failed in their duty to protect obligations as doctors.

Cornell Law School Definition of Negligence: “Negligence is a failure to behave with the level of care that someone of ordinary prudence would have exercised under the same circumstances.  The behavior usually consists of actions, but can also consist of omissions when there is some duty to act (e.g., a duty to help victims of one’s previous conduct).”

If Dr. Better-doctor and Dr. Bad-doctor had performed their duties with proper care, you wouldn’t be in this situation, and I wouldn’t be needed.

But you are in this situation. So the attorney has some dancing to do. The attorney will need to discredit both reports because neither is accurate, but then restore Better-doctor while bashing Bad-doctor (using what can be used of value from his report).

Because the diagnostic criteria for Child Psychological Abuse is vague, Dr. Better-doctor can give the diagnosis of Child Psychological Abuse if she wants to – but then she’ll have to defend her diagnosis against challenges from the both parents – dad will say Dr. Better-doctor is incompetent and mom will say Dr. Better-doctor misdiagnosed child abuse earlier – so Dr. Better-doctor is in danger because of her ignorant, incompetent, negligent, and unethical malpractice – but we want to restore her and use her more accurate recommendations as much as she will make more accurate recommendations.

Rattle the cage of Dr Better-doctor, then provide support in guiding her back into established knowledge as far as she’ll go, allow the judge to make any last leap that Dr. Better-doctor doesn’t. There are child protection concerns. A protective separation is desired. But if the judge won’t protect the child (yet), get treatment sole-consent rights for mom, then get the accurate diagnosis of a Child Psychological Abuse diagnosis, then take the accurate diagnosis of child abuse back as a changed circumstance requiring a protective separation – a child protection response.

Once there is a formal child abuse diagnosis made by a licensed mental health professional, mom can use this for the remainder of the children’s development to stabilize the family whenever the dad tries to make the children pathological.

Attorney Role in Cross-Examination

The attorney can’t get lost in details. The attorney needs to present clear evidence, clear issues, and clear decisions for the judge. But the attorney can be vague as to the exact nature of the Child Psychological Abuse here – because there’s several options to choose from:

1) Factious pathology (FDIA) – There is worry that the father is creating a false attachment pathology in the child toward the mother. Use a cross-generational coalition and emotional cutoff for this argument, but use the term “false attachment pathology” to refer to it as well because this links to Factitious Disorder Imposed on Another (when you use the word “factitious” for false, you’ll tip the MH professional where the diagnosis is; FDIA) – but FDIA is too technical for the judge. Dr. Better-doctor may give a diagnosis of child psychological abuse for this feature – the father is allowing – encouraging – the child’s acting out with the mother to meet the father’s own emotional and psychological needs.

Q: Is Child Psychological Abuse a DSM-5 diagnosis, doctor?

Q: What is Child Psychological Abuse?

Q: Hypothetically doctor, if one parent is responsible for generating a child’s attachment pathology and conflict with the other parent to meet the pathological parent’s own emotional and psychological needs, would that be consistent with a possible DSM-5 diagnosis of Child Psychological Abuse?

Q: Are you concerned about possible Child Psychological Abuse in this family?” (is the doctor “concerned”? Yes. Is she diagnosing? No. But the judge is led right to the precipice and can make the leap if the judge thinks there’s child psychological abuse).

3) Shared (induced) persecutory delusion – The father has a persecutory delusion regarding the mother that he is inducing in the child – a shared (induced) encapsulated persecutory delusion, (Walters & Friedlander 2016). The definition of a persecutory delusion is provided by the American Psychiatric Association.

From the APA: “Persecutory Type: delusions that the person (or someone to whom the person is close) is being malevolently treated in some way.” (American Psychiatric Association, 2000)

Dr. Better-doctor likely won’t make a diagnosis of a persecutory delusion on the witness stand, but she can come close. Whenever the attorney characterizes the child’s and father’s beliefs he should emphasize the phrase “malevolently treated in some way by the mother’s parenting”. Drive the phrase “malevolently treated in some way” into the judge’s awareness – because that’s what the persecutory delusion diagnosis turns on – a fixed and false belief that the child is being “malevolently treated in some way” by the normal-range parenting of the targeted parent.

Dr. Better-doctor will back away because she’s not comfortable with delusional diagnoses, Walk her close using the Walters & Friedlander quote and the definition from the APA – these are safe for her to agree with – then allow her to back-off just a tad on the diagnosis by giving her qualifiers in the question:

Q: Hypothetically doctor, if an allied parent is creating, inducing, a shared persecutory delusion in the child toward the other parent, would that possibly meet criteria for possible Child Psychological Abuse?

Q: Would what you’re describing in this sentence of your report be consistent with a diagnosis of possible Child Psychological Abuse by the father?

If possible, what the attorney will want to do with Dr. Better-doctor is to get all the issues presented clearly and get her as close as possible to a Child Psychological Abuse diagnosis as she’ll go by giving her qualifiers that allow her to escape formal diagnosis… then wrap it all up by placing the issues all together.

Q: So Dr. Better-doctor, is it fair to say that there are professional concerns about possible Child Psychological abuse because of the father’s pathogenic parenting, the father’s apparent cross-generational coalition with the child against the mother that’s destroying the child’s attachment bond to her mother, and because of a possible shared (induced) persecutory delusion from the father’s distorted parenting, is that an accurate characterization of your professional concerns for the father’s parenting?

Are there professional “concerns”? Yes. Dr. Better-doctor can support “concerns”. Is Dr. Better-doctor being asked to make the diagnosis? No, not exactly, not formally. She’ll remain safe from the father. She just has concerns – that’s reasonable.

The attorney will need to lay the groundwork across the previous question lines. When Dr. Bad-doctor testifies, he’ll be the target for all the professional fire. Brush back Dr. Better-doctor on her use of “parental alienation” and on Standard 2.04, but then switch to supported questions for her about family systems to rehabilitate her, let her agree with the ideas of “triangulation” and a “cross-generational coalition” and “emotional cutoff” – ask questions that make it seem like she knows, she can figure out the obvious definitions for each one.

Q; What’s family systems therapy, doctor? Is family systems therapy among the established scientific and professional knowledge of the discipline?

Q: What’s a “triangle” in the family, doctor? If I say the child is being “triangulated” into the spousal conflict what does that mean? (She’ll be on the spot, she’ll figure out the answer – a three person conflict with the child in the middle).

Q: What’s a “cross-generational coalition”, doctor? If I were to say the child has a “cross-generational coalition” with the father against the mother, what would that mean?

Q: What’s an “emotional cutoff”? If a child is emotionally cutoff from a parent, what does that mean?

Q: Here is a Structural family diagram from Salvador Minuchin, who is Salvador Minuchin? (a prominent family systems theorist). Does this diagram display the features we’ve been talking about, the child’s “triangulation” into the spousal conflict from a “cross-generational coalition” of the child with the father against the mother, resulting in an “emotional cutoff” in the child’s attachment bond to his mother, does this diagram display that? Where? Can you point those features out to me? (she’ll figure it out).

For Bad-doctor’s testimony, also switch off “parental alienation” (to take him entirely out of his comfort zone so he’s doing a personal risk assessment for each answer he makes – “will my answer get me in trouble?” – stress him as much as possible – move all lines forward together, switching back and forth in a reasonably coherent way, but one where he must constantly re-update the topic-context to evaluate the danger of his response in that context.

He’ll feel the lines moving in a direction, but he won’t be able to discern the direction. He’ll know it’s a dangerous direction though, because it started by asking him about ethical Standards – the question line puts his license at risk if he makes a wrong answer… but he’s not quite sure what the wrong answer is.

Lead him to making the wrong answer by making it look like it’s the safe answer. Use the word “possible” to draw him into thinking it’s a safe answer, anything is possible, but then use his admitted uncertainty to close the danger – that we need more information, i.e., that his opinions as contained in his recommendations and report are NOT based on information sufficient to substantiate his findings… he doesn’t know if there’s child abuse or not. Maybe yes, maybe no.

He thought the “possibility” in the question indicates it was a safe answer, anything is possible. However, it’s not a safe answer for exposure on Standard 9.01, not when he’s already conducted an assessment and the “possibility” is child abuse. He failed to take proper care in conducting his assessment.

Once you raise an ethical Standard – they’ll be worried. Back away from Dr. Better-doctor and guide her (the threat will now make her more compliant and cooperative with being gently led to safety) – go full bore on Bad-doctor when he testifies.

At the end, ask him these questions just to see what he’ll answer:

Q: Dr. Bad-doctor, given that you applied no established knowledge from family systems despite assessing a family conflict, from attachment despite assessing an attachment pathology, and from delusional thought disorders when assessing a possible persecutory delusion in the family, do you believe you met your ethical obligations under Standard 2.04 of the APA ethics code to apply the established scientific and professional knowledge of the discipline as the bases for your professional judgments?

Did you meet your ethical obligations under Standard 2.04, doctor?

Q: Dr. Bad-doctor, given that you applied no established knowledge from family systems despite assessing a family conflict, from attachment despite assessing an attachment pathology, and from delusional thought disorders when assessing a possible persecutory delusion in the family, do you believe you met your ethical obligations under Standard 9.01 of the APA ethics code in that your opinions contained in your recommendations and report are based on information and techniques sufficient to substantiate your findings?

Did you meet your ethical obligations under Standard 9.01, doctor?

Family Systems

Family systems constructs are a way to explain the pathology to the judge, they are more accessible than “persecutory delusions” and “factitious disorders”, and there is Minuchin’s diagram as a visual aid.

Is a cross-generational coalition child psychological abuse? No. Yes. Maybe. It’s complex.

First, the diagnostic definition for Child Psychological Abuse in the DSM-5 is vague. If a licensed MH professional wants to make the diagnosis for any reason, they can. If I decide as a doctor that the cross-generational coalition is child abuse – it’s child abuse, that’s how diagnosis works and what licensed means. We are authorized by the state to diagnose pathology. If I say you have schizophrenia, you have schizophrenia whether you like it or not. You can qualify for disability money and we can hospitalize you against your will based on my diagnosis.

That’s the power of diagnosis. If Dr. Better-doctor or Dr. Bad-doctor, or any license, says it’s Child Psychological Abuse (V995.51) that’s what it is. It’s like a judge making a determination of fact.

Then… they will have to defend their diagnosis against the challenge of it being a misdiagnosis – which is what we’re doing from the other direction. We’re saying they missed the diagnosis of child abuse rather than that they made the wrong diagnosis of child abuse (they made no diagnosis at all, are they making recommendations for cancer or recommendations for diabetes?).

They are both highly vulnerable on no-diagnosis (not even a “Rule-Out” as a possibility).

No Diagnosis

Q: If there was child abuse, doctor, would you diagnose that and tell the Court, or would you withhold a child abuse diagnosis from the Court?

Q: In your report, you didn’t make a diagnosis of Child Psychological Abuse, did you doctor?

Q: What is Child Psychological Abuse, doctor? Hypothetically, would creating a shared persecutory delusion in the child toward the other parent that then destroys the child’s attachment bond toward that parent, could that potentially be child psychological abuse?

Q: Since you did NOT give a Child Psychological Abuse diagnosis, doctor, are you saying that there is NO possibility that there is Child Psychological Abuse in this family?

A: No, it’s possible.

Q: It’s possible there’s Child Psychological Abuse occurring in the family, is that possible?

A: It’s possible.

Q: Show me in your report where you discuss that possibility?

Q: What is a Rule-Out diagnosis, if you put Rule-Out (R/O) next to a diagnosis, what does that mean?

A: That the diagnosis is a possibility.

Q: You didn’t even put Child Psychological Abuse as a Rule-Out in your report, did you? But now you’re saying it’s a possibility. But you didn’t disclose this possibility to the Court, did you? Show me where in your report you informed the Court of this possibility and discussed the possibility of Child Psychological Abuse.

Q:  If child abuse remains a possibility, would you recommend we get an additional risk assessment or that possibility?

A: Yes.

Q: Where in your report do you make that recommendation? Show me where you recommend an additional assessment for possible Child Psychological Abuse is needed?

Q: If child abuse and spousal abuse are possible in the family, why didn’t you disclose that to the Court and discuss those possibilities, Dr. Bad-doctor?

Q: Do mental health professionals have duty to protect obligations? What is the duty to protect obligation for a doctor, what does that mean?

Q: Your assessment took seven months and you met with everyone in the family conducting a comprehensive assessment of all the factors, and yet we STILL need ANOTHER assessment for possible child psychological abuse. Did you fail in your duty to protect the child, doctor?

A: No. I fulfilled my duty to protect obligations.

Q: If it’s possible there’s child abuse and we STILL need ANOTHER assessment even after your assessment, and you didn’t disclose the possibility of Child Psychological Abuse to the judge or discuss this possibility in your report, what exactly did you DO to protect the child from the possible Child Psychological Abuse?

Craig Childress, Psy.D.
Clinical Psychologist, CA PSY 18857