Most Pennsylvania family law practitioners know about the 2003 Commonwealth Court decision in Grossman v. State Board of Psychology, 825 A.2d 748 (Pa. Commonwealth 2003). I am sure all psychologists are familiar with the case. Recently the Pennsylvania State Board of Psychology, the body responsible for licensing psychologists in the commonwealth, modified its rules to essentially abrogate the Grossman decision. While it might not seem so at first blush, these changes are much more evolutionary than revolutionary.

By way of background, the Grossman decision arises out of a custody case and custody evaluation gone wrong. The facts go back to 1996. Mother and father were preparing for a custody trial, and all parties had an assessment by a psychologist. That psychologist did her testing, conducted her interviews, wrote a report and was prepared to testify at trial. The mother and her attorney hired a second psychologist, Dr. Grossman, to critique the first psychologist’s report. That, in and of itself, is not usual and not an ethical violation for a psychologist.

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