regarding christian wolff
503.381.2032
christian@christianwolff.com
Documents Related to Christian Wolff’s 2014 Suspension
Anyone viewing Christian Wolff’s profile on the Oregon Board of Psychology (OBOP)* website will see that Christian Wolff had his professional license suspended for 1 year (December 2013 to December 2014). What they will not see emphasized is Christian’s veritable win in an appellate hearing. Though OBOP posted the REVERSE & REMAND order of the appellate court on their site, they have refused to post the document which ordered OBOP to pay Christian Wolff’s attorney fees and costs. OBOP has also refused to post the documents related to charges leveled against Mr. Wolff alleging that some of Christian’s Continuing Education Units (CEU) did not qualify for credit upon review in 2015.
The three documents are posted here. Again, one of the documents can be found on the OBOP site. Two of the documents, OBOP has refused to publicize or post despite more than a dozen appeals by Christian Wolff for them to do so.
Excerpt from Apellate Court’s Reverse & Remand Decision in Three Sequential Paragraphs
“Viewing that evidence in the light most favorable to petitioner, a reasonable factfinder, considering the totality of the circumstances, could find that petitioner’s use of “PsyA,” “Master of Arts Clinical Psychology,” and “practicing psychology,” would not have misled or deceived the public into believing that petitioner had a doctorate in psychology. For example, petitioner’s use of “PsyA” in conjunction with references to his license as a psychologist associate and other surrounding contextual clues does not establish, as a matter of law, that petitioner was using “PsyA” to represent his degree. Nothing in the record establishes that a degree designation (rather than a license designation) always follows a person’s name. Further, 51*51 the record does not establish, as a matter of law, that the public would have understood “PsyA” to represent a doctorate in psychology, particularly given other contextual clues in the surrounding text that petitioner was a licensed psychologist associate.[9]
Similarly, a reasonable factfinder could conclude—on this record—that the public would not be misled into believing that petitioner had a doctoral degree in clinical psychology by listing his degree as “Master of Arts Clinical Psychology.” Again, viewing that description in the light most favorable to petitioner, a reasonable factfinder could find that petitioner’s description of his degree would not have misled the public into believing that he had a doctorate in psychology. Similarly, on this record, a reasonable factfinder could find that petitioner’s reference to “practicing psychology” was not misleading or deceiving given the surrounding textual clues and the totality of the circumstances.
The ALJ’s conclusion that petitioner’s conduct also violated ORS 675.020(1)(b) is subject to similar problems. We understand the ALJ to have concluded that, because petitioner made representations that would have misled the public into believing that he held a doctorate in psychology and was a licensed psychologist, he violated ORS 675.020 (1)(b)’s prohibition against representing oneself as a psychologist.[10] We have rejected the conclusion that petitioner’s representations necessarily would have misled the public as a matter of law; consequently, and for similar reasons, summary determination on the issue of whether petitioner’s conduct violated ORS 675.020(1)(b) was also inappropriate.”
Briefly, it is Wolff’s hypothesis that the Oregon Board of Psychology refuses to publish the Attorney Fee Document on their site (or anywhere) because it would make it too easy for the casual reader to discern that Wolff won in this matter despite appearances to the contrary.
Briefly, it is Wolff’s opinion that the matter of Wolff’s 19 “Non-qualifying” Continuing Education Units (CEU) was an act of harassment against him by the Oregon Board of Psychology. Wolff considers the assessment of his CEUs as non-qualifying to be absent of all merit, petty, and an act of awkward and erroneous hair-splitting unbecoming of a regulatory board.
Excerpt from the Admiistrative Law Judge’s (ALJ) & Findings on the Matter in Two Sequential Paragraphs
“The Board’s 2012 overview was significantly different from its current 2015 version. The 2012 version laid out the prerequisite requirements and then included the former OAR 858-040-0035(2) list of programs as a subsection beneath the prerequisite requirements. A licensee could reasonably conclude from that format that the list was not its own separate requirement. In the 2015 version, the Board changed the format so that the prerequisite requirements and the list of qualifying programs are equivalent sections, rather than one a subsection of the other. Additionally, in the 2015 version, the Board added the language that a CE activity must satisfy the prerequisites requirement and be a listed qualifying program. This language was absent in the 2012 version. Therefore, the 2012 overview failed to make clear to licensees that a CE activity must meet both the prerequisite requirements and be a listed qualifying program to qualify for CE credit.
During the hearing, Mr. Wolff expressed his genuine belief that Group Psychotherapy and Give Sorrow Words qualified as CE credit. The programs satisfied the prerequisite requirements of former OAR 858-040-0035(1), and the Board’s 2012 overview failed to clarify that a CE activity also had to be a listed qualifying program to qualify for CE credit. As explained previously, Mr. Wolff’s interpretation of former OAR 858-040-0035, that compliance with subsection ( 1 ) was enough to qualify a program for CE credit, was also a plausible interpretation of the rule. Ultimately, the record was clear that Mr. Wolff had a good faith belief that the Group Psychotherapy and Give Sorrow Words programs would qualify for CE credit pursuant to former OAR 858-040-0035. Given Mr. Wolff’s good faith belief in the adequacy of these programs. the ALJ found that it is not appropriate to assess a civil penalty against Mr. Wolff. The Board will not disturb the ALJ’s finding.”
Anticipated Question: Given the material presented on this page, why has Mr. Wolff not pursued more appeals?
Answer: The briefest reason Christian has not sought further appeals on each of these two matters is money. The OBOP simply out-monied Mr. Wolff. There are other reasons too. All this has been made quite complex by OBOP. Nevertheless, by far, the greatest obstacle to justice in this matter is Mr. Wolff’s lack of the amount of money that further appeals require.
* The Oregon Board of Psychology (OBOP) was known as the Oregon Board of Psychologist Examiners (OBPE) prior to January 1, 2015.