• The Alaska Supreme Court ruled that a pastoral counseling center could be sued by a woman who was sexually seduced by a counselor. The woman claimed that she had visited the counselor on several occasions, and that the pastoral counselor "negligently handled the transference phenomenon" by taking advantage of her sexually. She allegedly suffered severe emotional injuries, and as a result sued the center and two of its directors for damages. She claimed that the center was legally responsible for the counselor's misconduct on the basis of "respondeat superior"—a legal theory the makes an employer responsible for the actions of its employees committed within the scope of their employment. In explaining the "transference phenomenon," the director of the center explained that "transference is a phenomenon that occurs that is similar to a state of dependency in which the client begins ...
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