DISCIPLINE COMMITTEE OF THE

ONTARIO COLLEGE OF SOCIAL WORKERS AND SOCIAL SERVICE WORKERS

Indexed as:

Ontario College of Social Workers and Social Service Workers v Houston, 2025

ONCSWSSW 6

Date:

20250610

BETWEEN:

THE ONTARIO COLLEGE OF SOCIAL WORKERS AND SOCIAL SERVICE WORKERS

• and -

JENNIFER HOUSTON

PANEL:

Rita Silverthorn

Chair, Professional Member

Sana Imran

Professional Member

Molly Luu

Public Member

Appearances:

Ben Kates, counsel for the College

Jennifer Houston, the Registrant, self-represented

Edward Marrocco, Independent Legal Counsel to the Panel

Heard:

November 15, 2024

DECISION AND REASONS FOR DECISION

This matter came on for hearing before a panel of the Discipline Committee (the “Panel”) on November 15, 2024, at the Ontario College of Social Workers and Social Service Workers (the “College”), by way of videoconference. The Panel released its decision on the misconduct allegations, penalty and costs orally at the hearing with reasons to follow. These are the Panel’s reasons for decision.

Publication ban

This proceeding is the subject of a publication ban. The Panel has ordered that no details or information may be reproduced about this proceeding which may directly or indirectly cause the individuals referred to in this matter as C1 and C2 to be publicly identifiable.

The Allegations

In the Notice of Hearing dated December 9, 2022, Jennifer Houston (the “Registrant”) is alleged to be guilty of professional misconduct pursuant to the Social Work and Social Service Work Act, 1998, SO 1998, c 31 (the “Act”) in that he is alleged to have engaged in conduct that contravenes the Act, Ontario Regulation 384/00 (the “Professional Misconduct Regulation”), Schedule “A” to By-law No. 66 of the Ontario College of Social Workers and Social Service Workers, being the Ontario College of Social Workers and Social Service Workers Code of Ethics (the “Code of Ethics”), and Schedule “B” to By-law No. 66 of the Ontario College of Social Workers and Social Service Workers, being the Ontario College of Social Workers and Social Service Workers Standards of Practice Handbook (the “Handbook”).

The allegations set out in the Notice of Hearing and the particulars of those allegations are as follows:

I. The following are particulars of the said allegations:

1. At times relevant to the allegations, you were a registered social worker with the Ontario College of Social Workers and Social Service Workers (the “College”). At all relevant times, you provided social work services through your private practice “Jennifer Houston Counselling Services”.

2. From time to time between the period July 16, 2021 and April 8, 2022, you provided social work services to clients C1 and C2, including counselling and/or psychotherapy. C1 and C2 are married, and the services you provided to C1 and C2 during that time included couples counselling. C1 and C2 attended sessions both together and privately on their own. C1 and C2 attended at least 12 sessions with you, either separately or together, between August 9, 2021 and February 3, 2022.

3. Through your provision of social work services to C1 you knew no later than October 4, 2021 that C1 was a vulnerable client, and he consulted with you from time to time regarding his mental health and drug use.

4. In and around October 2021, you were in an accident involving a motor vehicle and suffered injuries, including a head injury. Following the accident, you temporarily ceased providing social work services on account of your injuries. You resumed providing social work services no later than January 17, 2022. On April 8, 2022, you advised your clients that you were taking a leave of absence for medical reasons. In and around June 2022 you notified the College of your intention to resign your certificate of registration with the College, and the College cancelled your certificate effective August 5, 2022.

5. Between approximately January and April 2022, you engaged in the practice of social work while suffering from an illness or dysfunction that you knew or ought to have known reasonably impaired your ability to practice.

6. On or about February 3, 2022, during or after a counselling session with C1, you began a personal and sexual relationship with C1 that lasted until approximately May 2022. Between approximately February and May 2022, you violated professional

boundaries; and/or engaged in sexual intercourse or another form of physical sexual relations; touching of a sexual nature; and/or behaviour or remarks of a sexual nature with C1

7. On or after February 3, 2022, you advised C1 that you would no longer provide C1 with social work services. You did not advise C2 you would no longer provide her with social work services. C2 continued to believe that you were her social worker until at least April 8, 2022.

8. Between approximately February and May 2022, you engaged in a series of boundary violations, conflicts of interest, and/or failed to ensure that the needs and interest of your clients, C1 and C2, remained paramount, including, but not limited to:

a) staying the same residence as C1 from time to time between February and April 2022;

b) attending at hotels with C1;

c) using drugs and/or alcohol with C1;

d) exchanging frequent personal text and/or email messages with C1, including messages of a sexual nature;

e) requesting and accepting funds from C1;

9. From time to time between approximately February and May 2022, you disclosed information to C1 that you attributed to C2 and advised had been conveyed to you by her during private counselling sessions. To the extent you were telling the truth, you improperly disclosed information concerning or received from your client C2. To the extent you were not telling the truth, you misled C1. In any event, you acted in a conflict of interest with C2 and C1 and failed to ensure that their needs and interests remained paramount.

10. Your conduct harmed both C1 and C2, who feel they were manipulated by you. C1 was not ready to stop receiving social work services at the time you initiated an intimate relationship on February 3, 2022, yet you did not make reasonable efforts to arrange alternative or replacement services after you purported to terminate the client relationship.

II. It is alleged that by reason of engaging in some or all of the conduct outlined above, you are guilty of professional misconduct as set out in section 26(2)(a) and (c) of the Act:

a) In that you violated Section 2.2 of the Professional Misconduct Regulation by failing to meet the standards of the profession and in particular:

i. Principle I of the Handbook (commented on in Interpretations 1.5 and 1.6) by failing to be aware of your values, attitudes and needs and how those impact on your professional relationship with clients; by failing to

distinguish your needs and interests from those of your clients; and by failing to ensure that, within your professional relationship, clients’ needs and interests remained paramount.

ii. Principle II of the Handbook (commented on in Interpretations 2.2, 2.2.1, 2.2.2, 2.2.3, 2.2.4, 2.2.6, and 2.2.8) by:

A. failing to ensure clients are protected from an abuse of power, including sexual misconduct, during and after the provision of professional services and/or failing to establish and maintain clear and appropriate boundaries in a professional relationship;

B. engaging in a professional relationship that constitutes a conflict of interest and/or in a situation in which you ought reasonably to have known that the client or former client would be at risk; failing to evaluate professional relationships and other situations involving clients or former clients for potential conflicts of interest; failing to avoid conflicts of interest and/or dual relationship with clients or former clients that could impair your professional judgment or increase risk of exploitation or harm to clients or former clients;

C. engaging in sexual relations with a client or person where those relations, combined with the professional relationship, would create a conflict of interest;

D. using information obtained in the course of a professional relationship and/or using your professional position of authority, to improperly influence, harass, abuse or exploit a client or former client;

E. soliciting or using information from clients to acquire, either directly or indirectly, advantage or material benefits;

F. WITHDRAWN BY REQUEST OF THE COLLEGE; and

G. engaging in conduct that could reasonably be perceived as reflecting negatively on the profession of social service work;

iii. Principle III of the Handbook (commented on in Interpretations 3.7) by:

A. by failing, in the context of a personal relationship with a client or former client, to assume full responsibility for demonstrating that the client or former client was not exploited, coerced or manipulated, intentionally or unintentionally;

iv. WITHDRAWN BY REQUEST OF THE COLLEGE

v. Principle VIII of the Handbook (commented on in Interpretations 8.1, 8.2, 8.7 and 8.8) by:

A. failing to ensure that sexual misconduct does not occur;

B. engaging in sexual intercourse or another form of physical sexual relationship; touching of a sexual nature; and/or behaviour or remarks of sexual nature with a client;

C. engaging in sexual relationship with a client to whom you provided psychotherapy and/or counselling services following the termination of the professional relationship;

b) In that you violated Section 2.5 of the Professional Misconduct Regulation by abusing a client sexually, psychologically or emotionally, including sexually abusing a client within the meaning of subsection 43(4) of the Act;

c) In that you violated Section 2.6 of the Professional Misconduct Regulation by using information obtained during a professional relationship with a client or using your professional position of authority to coerce, improperly influence, harass, or exploit a client or former client;

d) WITHDRAWN BY REQUEST OF THE COLLEGE

e) In that you violated Section 2.36 of the Professional Misconduct Regulation by engaging in conduct or performing an act relevant to the practice of the profession that, having regard to all circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional.

Registrant’s position

The Registrant admitted the allegations set out in the Notice of Hearing other than those that were withdrawn. The Panel conducted an oral plea inquiry and was satisfied that the Registrant’s admission was voluntary, informed and unequivocal. The Agreed Statement of Facts tendered in this proceeding, discussed below, also indicates that the Registrant’s admissions have been made freely.

The evidence

The evidence was tendered by way of an Agreed Statement of Facts, which provided in relevant part as follows.

A. Overview

1. Jennifer Houston (the “Registrant”) provided social work services, including couples counselling, to the complainants, C1 and C2 (together, the “Clients”), between at least August 9, 2021 and February 3, 2022. At all materials times C1 and C2 were married and had one child together.

2. On or about October 15, 2021, the Registrant was in an ATV accident in which she suffered injuries to her ankle and head. The Registrant took a leave of absence following the accident but began practicing social work again by January 17, 2022. She resumed her sessions with the Clients at that time, but most of those sessions were with C1 only.

3. Following a private session on February 3, 2022, the Registrant and C1 entered into a personal and sexual relationship. The relationship carried on without the knowledge of C2 until April 26, 2022 and ended or about May 3, 2022. In and around early April 2022, prior to the end of her relationship with C1, the Registrant advised her Clients that she was taking a leave of absence because of her health.

4. The Registrant resigned her certificate of registration in June 2022, and it was cancelled effective August 5, 2022.

B. The Registrant’s Background

5. The Registrant first registered with the Ontario College of Social Workers and Social Service Workers (the “College”) as a Social Worker on February 15, 2013 after obtaining a Master’s Degree from Grand Valley State University in Michigan, U.S.A. in 2012.

6. At all relevant times, the Registrant provided social work services through her private practice, “Jennifer Houston Counselling Services”.

7. The Registrant is not registered with the College as of the date of this Agreed Statement of Facts. The Registrant provided the College with notice of her intention to resign her certificate of registration on June 16, 2022, and the College cancelled her certificate of registration effective August 5, 2022.

C. Social Work Services Originally Provided by the Registrant to C1 and C2

8. The client relationship between the Clients and the Registrant began in the summer of 2021. C2 initially contacted the Registrant by email and they discussed issues in the relationship between C2 and C1 on July 16, 2021. The Clients attended their first couples counselling session with the Registrant on August 9, 2021.

9. One or both of C1 and C2 attended 12 “counselling/psychotherapy” sessions with the Registrant, either separately or together, between August 9, 2021 and February 3, 2022. C2 attended approximately three individual sessions with the Registrant, and C1 attended approximately five or six individual sessions. Both C1 and C2 disclosed information to the Registrant in their individual sessions that they had not disclosed to one another.

10. On or about October 14, 2021, C2 encouraged C1 to start seeing the Registrant alone in private sessions. C2 had told the Registrant in a previous session she felt that C1 would be more forthcoming in counselling sessions if he attended on his own. C1 went on to attend counselling without C2 on that date and from time to time thereafter.

D. C1’s Mental Health

11. C1 began experiencing mental health issues not long after he began seeing the Registrant professionally. He took a leave of absence from work in September 2021 due to a stressful workplace incident and remained off work as of May 19, 2022. C2 first observed what she described as “psychosis” in C1 on September 30, 2021. C1’s condition made him see and hear things and act paranoid. These symptoms continued to manifest from time to time in the months that followed.

12. The Clients raised C1’s mental health concerns with the Registrant. During an October 4, 2021 session, C1 spoke about stressors at his workplace. C1 told the Registrant that he “can’t sleep” and that he “feels like he can hear things in the house”. He also told the Registrant that he was “fearful that his wife and baby will be hurt”, and that “he’s afraid of intruders”. C2 told the Registrant that she was worried about C1’s lack of sleep and “agitation”. The Registrant created a safety plan for C1.

13. In January 2022, C1 moved out of the Clients’ family home to live with his sister because of concerns about his mental stability and its impact on his daughter. C1 left his sister’s home to live with friends in and around February 2022.

E. The Registrant’s Temporary Cessation of Practice

14. The Clients’ therapy sessions with the Registrant ceased for a period in the fall and winter of 2021 after and as a result of the Registrant’s October 2021 ATV accident. On November 8, 2021, the Clients attended for a session with the Registrant, but the Registrant was not there. The following day, on November 9, 2021, the Registrant texted C2 to apologize. She advised that she had been in an accident in mid-October and was not working:

“I have to apologize. There was an email sent out 3 Fridays [sic] ago by my colleague. Obviously she missed people and for that I apologize. I was in a serious accident and suffered a brain injury and received a brand new ankle. The doctor said I should be able to return to work next week. I will return part time and hopefully be back 100 percent the following week …

When [colleague] sent out the email my prognosis was not so good she just said out or [sic] office indefinitely. I am happy to say “i kicked butt” [sic] and came home in 3 days after a coma and intubation! I am feeling so much better but am just coming off the gross medication, those combined with the head injury would not make me a very competent therapist! I will be back next week…”

15. The Registrant did not have any counselling sessions with the Clients between October 14, 2021 and January 17, 2022. On January 17, 2022, she met C1 for a private session.

F. Social Work Services Provided by the Registrant to the Clients upon Resuming Practice

16. C2 attended only a few sessions with the Registrant after October 14, and C1 attended most of the sessions after the Registrant’s accident on his own. C1 saw the Registrant more frequently than C2 did because of his mental health issues.

17. C1 attended at least four sessions with the Registrant by himself in January and February 2022. C1 told the Registrant that he was living with his sister after having separated from C2. The Registrant and C1 discussed the issues he was having in his relationship with C2, including their separation, on January 17, 26, and 31, 2022. They discussed his drug use on January 26 and 31, 2022.

G. The Registrant Engaged in Personal and Sexual Relationship with C1

18. C1’s final formal session with the Registrant was on February 3, 2022. He returned to the Registrant’s office that night. He and the Registrant drank alcohol and engaged in sexual intercourse that evening.

19. C1 was using drugs and alcohol in February 2022. He was drinking a bottle of alcohol every night and using drugs with his friends. C1 was also taking sleeping pills and anxiety pills that had been prescribed by a nurse practitioner. He suffered from bouts of alcoholism, both stress and cocaine-induced psychosis, and seeing and hearing things. If the Registrant were to testify, her evidence would be that she was not aware of the nature and frequency of C1’s drug and alcohol use.

20. C1 and the Registrant began dating following their first romantic encounter on February 3, 2022. In and around mid-February 2022, C1 was living with friends. The Registrant stayed at the residence with C1 off and on, between February and May 2022.

21. Details of the romantic and intimate relationship between the Registrant and C1 included the following:

(a) On one occasion, at C1’s invitation, the Registrant accompanied C1 to his and C2’s home while C2 was out and their daughter was sleeping upstairs.

(b) The Registrant met C1’s brother-in-law.

(c) C1 met the Registrant’s son.

(d) C1 once loaned the Registrant’s son his car.

(e) The Registrant texted C1 on at least one occasion to ask if he wanted a bottle of alcohol.

(f) The Registrant drank alcohol and used marijuana with C1

(g) C1 attended the impound that was holding the Registrant’s vehicle and paid at least

$100 to stop a daily charge.

(h) C1 paid for things for the Registrant when they were together from time to time.

(i) C1 and the Registrant rented and stayed together at hotel rooms from time to time.

H. Communications between the Registrant and C1

22. Between mid-February and May 2022, the Registrant and C1 regularly exchanged communications of a sexual nature that were not of a clinical nature or appropriate for any service provided by the Registrant. For instance, on February 15, 2022, C1 emailed the Registrant, “…I am thinking of you. Xoxox. Email me if you want :)”. C1 and the Registrant also exchanged text messages to each other saying, “Love you”. The Registrant and C1 engaged in the following text exchange of a sexual nature:

R.1 Sweet dreams.

C1 You okay.

R. Yes baby. I dont [sic] want to keep you up. I desperately want to lay beside you but I cant [sic] shut by mouth. I don’t want to fuck anything up with you and [child’s name] [heart emoji]. I love you. I’m sorry. Go sleepy.

C1 What’s my code word.

R. For?? Sex?

C1 Yes.

R. Vanilla

23. Also during the period of February to May 2022, including while C2 remained a client of the Registrant, the Registrant and C1 communicated and exchanged text messages about C2 For example, on April 14, 2022, the Registrant and C1 engaged in the following text exchange:

R. Spend your time feeling vengenable qbout [C2]. Tell me 3 things it gets you. [sic]

I wish I could make you feel more happy than you are angry. I sorry [sic]

C1 Please come up to me.

R. Hey. Sorry babe fell asleep. I love you truly.

I. The Professional and Therapeutic Relationship after February 3, 2022

24. When C1 went to his February 3, 2022 appointment, he did not think it was going to be his last counselling session. He had no intention of terminating the therapeutic relationship.

¹ “R.” indicates the Registrant.

25. C1 found it hard that he lost his relationship with his therapist. While they were dating, C1 would sometimes indicate to the Registrant that he needed to talk to his therapist as opposed to his girlfriend.

26. C2 believed that her therapeutic relationship with the Registrant remained ongoing until at least April 8, 2022. The Registrant did not advise C2 on February 3, 2022 that she would no longer provide her with social work services, but, in and around February 2022, the Registrant stopped responding to C2’s text messages. If she were to testify, the Registrant’s evidence would be that she had understood that C1 had communicated to C2 that he was no longer attending counselling.

27. Nevertheless, C2 continued to text the Registrant about appointments, including on March 22 and March 29, 2022. C2 did not know about the relationship between C1 and the Registrant until late April 2022.

28. On March 29, 2022, one of the Registrant’s colleagues expressed concerns to the Registrant about her behaviour and asked her to take a break from practising social work. The colleague is a registered social worker who shared office space with the Registrant but operated an independent practice. Towards the end of February and early March 2022, the colleague observed less stability and structure in the Registrant’s personal life, significant ups and downs in mood, and increased alcohol intake outside of work. On April 8, 2022, the Registrant sent an “absence alert” email to her clients, including C2, advising that she was taking an indefinite sick leave.

29. If she were to testify, the Registrant’s evidence would be that she stopped seeing clients prior to March 29, 2022 but is unable to say with precision when that occurred.

J. End of Intimate and Sexual Relationship

30. On April 26, 2022, C2 looked at C1’s phone after perceiving him as acting strange. C2 saw extensive text messages between C1 and a person that C2 thought was the Registrant and who referred to herself as “Jen”. C2 also saw a Facebook message sent by “[registrant]” to C1 that said, “hey babe.” The Facebook profile associated with the message had pictures of the Registrant. That evening, C1 admitted that it was the Registrant who had sent the messages.

31. On April 26, 2022 at 7:32 pm, C2 texted the Registrant and confronted her about her relationship with C1.

32. The relationship between the Registrant and C1 ended in and around late April 2022.

33. The Registrant was admitted to hospital in early May 2022.

34. On May 1, 2022, the Registrant disclosed to a colleague that she had been in an intimate relationship with a client for three months. The Registrant had told the colleague earlier in the relationship that she was dating someone but had declined to provide C1’s name citing “personal privacy”. On May 3, 2022, the Registrant texted the colleague to advise that the relationship with C1 “had been ended”.

35. As of May 12, 2022, C1 was back living with C2 but stayed with his sister from time to time. He had started trying to make amends with C2. As of November 15, 2022, C1 had been sober for a little over a month, was seeing a psychiatrist, and was enrolled in Alcoholics Anonymous.

K. The Registrant’s Health Circumstances

36. The Registrant acknowledges and admits that she is responsible for the conduct set out in this Agreed Statement of Facts and that her health circumstances do not excuse it.

37. If she were to testify, the Registrant’s evidence would be that her conduct during the winter and spring of 2022 is not representative of the qualities she displayed as a social worker over the balance of her career. She would testify, further, that it was only in May 2022, after being admitted to hospital and receiving treatment and psychoeducation about her brain injury that she became aware of the full extent of her injuries suffered in October 2021 and their implications.

L. Admissions of Professional Misconduct

38. The Registrant agrees that the following are standards of the profession, as set out in the Code of Ethics and Standards of Practice Handbook (the “Handbook”):

(a) Principle I addresses relationships with clients;

(b) Principle II addresses competence and integrity;

(c) Principle III addresses responsibility to clients; and

(d) Principle VIII addresses sexual misconduct.

39. The Registrant admits that by reason of engaging in the conduct outlined above, she is guilty of professional misconduct as set out in section 26(2)(a) and (c) of the Social Work and Social Service Work Act, 1998, S.O. 1998, c. 31 (the “Act”):

(a) In that she violated Section 2.2 of the Professional Misconduct Regulation by failing to meet the standards of the profession and in particular:

i. Principle I of the Handbook (commented on in Interpretations 1.5 and 1.6) by failing to be aware of her values, attitudes and needs and how those impact on her professional relationship with clients; by failing to distinguish her needs and interests from those of her clients; and by failing to ensure that, within her professional relationship, clients’ needs and interests remained paramount.

ii. Principle II of the Handbook (commented on in Interpretations 2.2, 2.2.1, 2.2.2, 2.2.3, 2.2.4, and 2.2.8) by:

A. failing to ensure clients are protected from an abuse of power, including sexual misconduct, during and after the provision of professional services and/or failing to establish and maintain clear and appropriate boundaries in a professional relationship;

B. engaging in a professional relationship that constitutes a conflict of interest and/or in a situation in which she ought reasonably to have known that the client or former client would be at risk; failing to evaluate professional relationships and other situations involving clients or former clients for potential conflicts of interest; failing to avoid conflicts of interest and/or dual relationship with clients or former clients that could impair her professional judgment or increase risk of exploitation or harm to clients or former clients;

C. engaging in sexual relations with a client or person where those relations, combined with the professional relationship, would create a conflict of interest;

D. using information obtained in the course of a professional relationship and/or using your professional position of authority, to improperly influence, harass, abuse or exploit a client or former client;

E. soliciting or using information from clients to acquire, either directly or indirectly, advantage or material benefits; and

F. engaging in conduct that could reasonably be perceived as reflecting negatively on the profession of social service work;

iii. Principle III of the Handbook (commented on in Interpretation 3.7) by:

A. failing, in the context of a personal relationship with a client or former client, to assume full responsibility for demonstrating that the client or former client was not exploited, coerced or manipulated, intentionally or unintentionally;

iv. Principle VIII of the Handbook (commented on in Interpretations 8.1, 8.2, 8.7 and 8.8) by:

A. failing to ensure that sexual misconduct does not occur;

B. engaging in sexual intercourse or another form of physical sexual relationship; touching of a sexual nature; and/or behaviour or remarks of sexual nature with a client;

C. engaging in sexual relationship with a client to whom she provided psychotherapy and/or counselling services following the termination of the professional relationship;

(b) In that she violated Section 2.5 of the Professional Misconduct Regulation by abusing a client sexually, psychologically or emotionally, including sexually abusing a client within the meaning of subsection 43(4) of the Act;

(c) In that she violated Section 2.6 of the Professional Misconduct Regulation by using information obtained during a professional relationship with a client or using her

professional position of authority to coerce, improperly influence, harass, or exploit a client or former client; and/or

(d) In that she violated Section 2.36 of the Professional Misconduct Regulation by engaging in conduct or performing an act relevant to the practice of the profession that, having regard to all circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional.

M. Acknowledgements

40. The Registrant acknowledges and agrees that the Discipline Committee has ongoing jurisdiction over her and this proceeding pursuant to s. 13(3) of the Act.

41. Having had the opportunity to obtain independent legal advice, the Registrant has reviewed and understands the Notice of Hearing dated December 9, 2022 (the “Notice of Hearing”) and this Agreed Statement of Facts. The Registrant further acknowledges that she is entering into this Agreed Statement of Facts freely and voluntarily, without compulsion or duress.

42. This Agreed Statement of Facts constitutes a statement of facts agreed upon by the parties within the meaning of rule 13.02 of the Rules of Procedure of the Discipline Committee of the College.

43. The Registrant irrevocably acknowledges and agrees that all the facts in this Agreed Statement of Fact are true and accurate.

44. The College and the Registrant voluntarily admit the truth of the facts as recounted in this Agreed Statement of Facts.

45. The Registrant understands the nature of the allegations that have been made against her and that by voluntarily admitting these facts, she waives her right to require the College to otherwise prove these facts. The College and the Registrant agree that because of the admissions in this Agreed Statement of Facts, neither the College nor the Registrant needs to prove the facts recounted in this Agreed Statement of Facts through a full hearing with witness’s testimony and other evidence.

46. The College and the Registrant understand that, at a hearing into this matter, they may adduce additional evidence pertaining to some or all of the allegations contained in the Notice of Hearing that is consistent with the facts agreed to in this Agreed Statement of Facts. The College and the Registrant understand that, at a hearing into this matter, they are prohibited from adducing additional evidence that is inconsistent with the facts agreed to in this Agreed Statement of Facts.

47. The Registrant understands that the Panel of the Discipline Committee can accept that the facts herein constitute professional misconduct and, in particular, can accept her admissions as constituting professional misconduct.

48. The Registrant understands that if the Panel makes a finding or findings of professional misconduct against her, then the Panel’s decision and its reasons, and/or a summary of its

reasons including the facts contained herein and the Registrant’s name, as well as any reprimand ordered under section 26 of the Act, will be published in the College’s official Registrant publication, in the College’s register, on the College’s website, and/or in any other media-related format that is provided to the public and is deemed appropriate by the College pursuant to s. 26(5)(3) of the Act.

49. The Registrant understands that the Panel of the Discipline Committee can make orders as a result of a finding of professional misconduct, as described in the Notice of Hearing, and then would consider the appropriate penalty under section 26 of the Act. The Registrant understands that the Panel of the Discipline Committee might not accept a submission as to penalty or costs, even where jointly proposed by the parties.

50. The College and the Registrant consent to this Agreed Statement of Facts being filed with the Discipline Committee and provided to the Panel in advance of the hearing of this matter.

Decision of the panel

Having considered the admissions of the Registrant, the evidence contained in the Agreed Statement of Facts, and the submissions of counsel, the Panel found that the Registrant committed the acts of professional misconduct alleged in the Notice of Hearing and which remained after the College’s withdrawal requests. The Panel found that the Registrant’s conduct would reasonably be regarded by members of the profession as disgraceful, dishonourable, or unprofessional.

Reasons for decision

Having reviewed the materials filed jointly by the parties and after hearing submissions, the Panel was satisfied that the evidence contained in the Agreed Statement of Facts was sufficient to support the findings being requested by the College and was consistent with the Registrant’s admissions. The Panel found that the Registrant’s plea was fully informed, voluntary and unequivocal.

The Registrant provided counselling services to C1 and C2 over a period of several months, both as a couple and individually, with C1 being seen more often due to reported mental health concerns. C1 described their symptoms and reasons for being off work, which lead to their seeking out social work services, which were known to the Registrant. The Registrant was aware of their level of vulnerability and had taken steps to establish a safety plan. The Registrant admitted to engaging in a romantic relationship with C1, who was known to the registrant as vulnerable, and improperly exploited confidential information learned during the professional relationship with C1 and C2.

The Registrant did not adequately communicate an end to the therapeutic relationship with both C1 and C2, nor take steps to connect them with alternate services. This is after the Registrant stopped providing social work services and began engaging in a romantic and sexual relationship with C1. The Registrant neglected to consider the impact of this on both, C1 and C2 and did not respond to communication attempts from C2, who continued to reach out regarding social work services and appointments.

Under Part II (a), the College alleged that the Registrant engaged in professional misconduct by failing to meet the standards of the profession as set out in:

a. Principle I of the Handbook, as commented on in Interpretations 1.5 and 1.6. Principle I related to a registrant’s relationship with clients. By neglecting to appropriately end the therapeutic relationship with clients C1 and C2, and engaging in a romantic and sexual relationship with C1, the registrant failed to be aware of her values, attitudes and needs and how those impacts on her professional relationship. The registrant failed to distinguish her needs and interest from those of her clients to ensure that, within the professional relationship, her clients’ needs and interest remained paramount.

b. Principle II of the Handbook, as commented on in Interpretations 2.2, 2.2.1, 2.2.2, 2.2.3, 2.2.4, 2.2.6, and 2.2.8, related to ensure the therapeutic relationship between a Registrants and any clients are professional, boundaried, protected from an abuse of power, and protected from conflicts of interest. By engaging in a personal, romantic and sexual relationship with C1, the Registrant failed to ensure C1 and C2 were protected from an abuse of power, especially in a case where the Registrant was aware that the client would be at risk. The Registrant failed to evaluate their needs versus their professional responsibility and boundaries, and consider the risk of exploitation and harm to C1 and C2. The Registrant also admitted to using information obtained in the course of the professional relationship with C2 while engaging in a romantic relationship with C1, and engaged in conduct that reflects negatively on the professional social service work.

c. Principle III of the Handbook, as commented on in Interpretation 3.7, related to assuming responsibility for demonstrating a client is not exploited, coerced, or manipulated. By virtue of the Registrant not formally ending their therapeutic relationship with C1 and C2, engaging in a romantic and sexual relationship with C1 and failing to respond to C2’s attempts to communicate over the following months regarding social work services, the Registrant failed to ensure the clients were protected from exploitation, coercion or manipulation.

d. Principle VIII of the Handbook, as commented on in Interpretations 8.1, 8.2, 8.7, and

8.9 relating to sexual misconduct. By engaging in a romantic and sexual relationship with C1, the Registrant failed to prevent sexual misconduct and engaged in a sexual relationship with a client. Based on the admitted facts, the Registrant also engaged in a sexual relationship with a client whom the Registrant was providing counseling services.

Under Part II (b), the College alleged that the Registrant violated section 2.5 of the professional misconduct regulation as it relates to the abuse of a client sexually, psychologically, or emotionally. As established in the Agreed Statement of Facts, the Registrant engaged in a romantic and sexual relationship with C1. The evidence confirms C1 sought to speak with the Registrant in the Registrant’s therapeutic capacity while engaging in the romantic and sexual relationship with the Registrant, establishing a lack of clear supports being put in place for the client during a vulnerable time.

In Part II (c), the College alleged that the Registrant violated section 2.6 of the professional misconduct regulation by using information obtained during a professional relationship with a client or used their professional position of authority inappropriately. As set out in the Agreed

Statement of Facts, the Registrant shared confidential information that was provided during sessions by C2 to the Registrant, with C1 while engaging in the romantic and sexual relationship. This is not only contrary to standards of the profession, but also had the impact of improperly influencing and exploiting C1, given the separation C1 was going through at the time with C2.

In Part II (e), the College alleged that the Registrant violated section 2.36 of the professional misconduct regulation by engaging in conduct that would reasonably be regarded by members as disgraceful, dishonourable or unprofessional.

The Registrant admitted to all the allegations contained in the Agreed Statement of Facts. The Registrant’s boundary violations, romantic and sexual relationship with C1, and lack of consideration of her clients’ therapeutic needs was entirely improper and constitutes misconduct of the most serious kind: sexual abuse of clients. She exploited clients whom she knew were vulnerable and abused the position of trust and authority she held by virtue of the professional relationship. The Registrant’s conduct demonstrates serious moral failings.

Penalty submissions

The parties were in agreement on the issue of penalty. They presented a signed Joint Submission on Penalty (the “Joint Submission”) asking this Panel to make an order directing that:

a. The Registrant be reprimanded by the Discipline Committee, and the fact and nature of the reprimand be recorded on the College’s Register.

b. The Registrar be directed to revoke the Registrant’s certificate of registration.

c. The period of time during which the Registrant may not apply to the College for a new certificate of registration shall be fixed at five (5) years from the date of the Discipline Committee’s Order.

d. The Discipline Committee’s finding and order (or a summary thereof) shall be published, with identifying information concerning the Registrant included, in the College’s official publication and on the College’s website, and the results of the hearing shall be recorded on the Register and in any other media-related format that is provided to the public and is deemed appropriate by the College.

e. The Registrant shall pay costs to the College in the amount of $1,000 to be paid over a one- year period beginning January 1, 2025 in 24 monthly installments in accordance with a payment schedule attached to the Joint Submission.

f. If the Registrant fails to make any of the monthly payments the payment schedule set out in the agreed upon payment schedule, the entire amount of costs outstanding will become due immediately.

In support of its position, the College argued that the order proposed in the Joint Submission was appropriate and reflected the seriousness of the Registrant's professional misconduct. It was also submitted that the order served the public interest as well as the objectives of deterrence, protection, and remediation. College counsel noted principles and precedents in other disciplinary proceedings, as well as the mitigating and aggravating factors in this particular

case. The primary aggravating factors included the vulnerability of C1 and the acute breach of trust involving C2. The mitigating factors included the Registrant's lack of prior discipline history, her contrition, forthrightness, and sincerity in admitting to the professional misconduct, which spared C1 and C2 the burden of reliving the matter through witness testimony. Additionally, the Registrant's health circumstances, specifically an acquired brain injury suffered in October 2021, were put forward for the Panel’s consideration. College counsel noted specifically however that the direct impact of this injury on the Registrant’s misconduct remained unclear.

The College submitted that the proposed order of a reprimand, revocation, five-year prohibition on reapplication, publication, and costs was consistent with the mandatory provisions for cases of sexual abuse, and with previous orders made by the College in similar cases of sexual misconduct. The College also submitted that the proposed order was proportional to the Registrant's individual circumstances, which included as above her lack of discipline history, her admission of guilt, her contrition, and her health issues. The College further submitted that the proposed order respected the benefits of the joint submission process, which avoids the need for a full hearing and the potential harm to the clients, and promotes certainty and efficiency in the resolution of disciplinary matters. The College contended that the proposed order would not bring the administration of justice into disrepute or be contrary to the public interest, and that the panel should not reject it unless it meets the high threshold of being unhinged from the circumstances of the case.

Penalty decision

Having considered the findings of professional misconduct, the evidence and the submissions of the parties, the Panel accepted the Joint Submission and made an order consistent with the terms before the conclusion of the hearing day. Specifically, the Panel ordered that:

a. The Registrant shall be reprimanded by the Discipline Committee, and the fact and nature of the reprimand shall be recorded on the College’s Register.

b. The Registrar shall be directed to revoke the Registrant’s certificate of registration.

c. The period of time during which the Registrant may not apply to the College for a new certificate of registration shall be fixed at five (5) years from the date of the Discipline Committee’s Order.

d. The Discipline Committee’s finding and order (or a summary thereof) shall be published, with identifying information concerning the Registrant included, in the College’s official publication and on the College’s website, and the results of the hearing shall be recorded on the Register and in any other media-related format that is provided to the public and is deemed appropriate by the College.

e. The Registrant shall pay costs to the College in the amount of $1,000 to be paid over a one- year period beginning January 1, 2025 in 24 monthly installments in accordance with the payment schedule set out below.

f. If the Registrant fails to make any of the monthly payments the payment schedule, the entire amount of costs outstanding will become due immediately.

Payment Schedule

Amount ($)

Due Date

41.66

January 1, 2025

41.66

February 1, 2025

41.66

March 1, 2025

41.66

April 1, 2025

41.66

May 1, 2025

41.66

June 1, 2025

41.66

July 1, 2025

41.66

August 1, 2025

41.66

September 1, 2025

41.66

October 1, 2025

41.66

November 1, 2025

41.66

December 1, 2025

41.66

January 1, 2026

41.66

February 1, 2026

41.66

March 1, 2026

41.66

April 1, 2026

41.66

May 1, 2026

41.66

June 1, 2026

41.66

July 1, 2026

41.66

August 1, 2026

41.66

September 1, 2026

41.66

October 1, 2026

41.66

November 1, 2026

41.82

December 1, 2026

Reasons for decision on penalty

20The Panel recognized that an appropriate penalty must maintain high professional standards, preserve public confidence in the ability of the College to regulate its registrants, and, above all, protect the public. This is achieved through a penalty that considers the principles of general deterrence, specific deterrence and, where appropriate, rehabilitation and remediation of the Registrant's practice. The Panel also considered the principle that the Panel should accept a joint submission on penalty unless it is contrary to the public interest and would bring the administration of justice into disrepute.

21Both parties have entered the joint submission voluntarily and after careful consideration. The Panel accepted the joint submission provided by the parties as it aligns with the objectives of proper penalty order, specifically public protection, as well as specific and general deterrence. Misconduct of the nature found in this case would typically warrant an order of revocation of the Registrant's certificate of registration, as has been done, and the Registrant may not apply for a new certificate of registration before five (5) years from the date of the Panel's Order. Together with the reprimand and publication of the Panel's finding and Order, the Panel is satisfied that the above objectives are met.

22In sum, the joint submission is appropriate, reasonable, and satisfies the duty to protect the public interest. There will be a reprimand recorded on the public register, allowing the Panel to denounce the misconduct and convey disapproval directly to the Registrant. The recorded reprimand and additional terms in the Order will deter others in the profession from engaging in similar misconduct. In totality, the Order sends a clear message to the public and profession that misconduct of this nature is not tolerated by the College.

23As to the issue of costs, the agreed-upon amount of $1,000 and the related payment schedule are fair and reasonable in the circumstances of this case. The Panel saw no reason to interfere with the parties' agreement and issued the Order at the hearing accordingly.

I, Rita Silverthorn, sign this decision as chairperson of the Panel and on behalf of the Panel members listed below.

Date: June 10, 2025 Signed:

Rita Silverthorn, Chair

Sana Imran, Professional Member Molly Luu, Public Member

APPENDIX A - Reprimand

Ms. Houston, as part of its penalty order this Discipline panel has ordered that you be given a reprimand.

The fact that you have received this reprimand will be part of the public portion of the Register and, as such, part of your record with the College.

You will be given an opportunity to make a statement at the end of the reprimand if you wish. This will not be an opportunity for you to debate the merits of our decision.

The panel has found that you have engaged in professional misconduct in several ways.

You embarked upon an intimate and sexual relationship with a client with knowledge that it was not appropriate.

You engaged in an intimate and sexual relationship with a client that you knew to be vulnerable by virtue of the counselling services you provided to them.

You failed to ensure your clients were protected from an abuse of power including sexual misconduct, during and after the provision of professional services and did not maintain clear and appropriate boundaries in the professional relationship with your clients.

Your misconduct is a matter of profound concern to this panel. You have brought discredit to the profession and to yourself. Public confidence in this profession has been put in jeopardy. You have let down the public, the social work profession, and yourself.

We need to make it clear to you that your conduct is unacceptable. Of special concern to us is that:

You failed to properly terminate and communicate the therapeutic relationship. You did not facilitate a transfer of care to ensure the clients were receiving adequate alternate therapeutic support.

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College counsel’s comments respecting your sensitivity as to your clients’ need for privacy and to avoid their testimony in a public hearing and your willingness to work with the College reassures this panel that you have recognized the seriousness of your conduct.

Notwithstanding your voluntary cancellation of registration, the Panel has ordered the revocation of your certificate of registration with the College. This is the most serious penalty the Discipline Committee can impose.

We also want to make it clear to you that while the penalty that this panel has imposed upon you is a fair penalty, an even more significant penalty will almost certainly be imposed by another Discipline panel in the event that you are ever found to have engaged in professional misconduct again.

As we advised you earlier, you will now be given an opportunity to make a comment if you wish to do so. I remind you that this is not an opportunity for you to review the decision or debate the correctness of the decision. However, do you have any questions or do you wish to make any comments?

Thank you for attending today.