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Active U.S. Courts of Appeals

Canepa v. Board of Licensed Professional Counselors and Therapists

A counselor holds a clipboard of notes as he speaks with a client

Summary

The Oregon Board of Licensed Professional Counselors and Therapists fined licensed counselor Frank Canepa $89,636 for answering a client’s repeated demand to personally affirm same-sex relationships. Although Canepa had seen this client for over two and a half years and had never mentioned his personal views on same-sex relationships in at least 44 other sessions in which this topic came up, the client insisted for 20 minutes in one session that Canepa personally bless her same-sex relationship. Canepa eventually told her he could not personally affirm these relationships because of his Catholic faith.

Case Timeline

  • July 2023: Frank’s client repeatedly pressed him to disclose his personal view on same-sex relationships. After multiple attempts to avoid sharing it, Frank explained that he could not personally affirm same-sex relationships because of his Catholic faith. A complaint was later filed against Frank with the state’s licensure board.
  • January 2025: An administrative law judge heard Frank’s case and concluded that Frank violated the American Counseling Association Code of Ethics. The judge recommended professional discipline that included making Frank pay legal costs up to $100,000 and take six hours of continuing education.
  • August 2025: The Board adopted the judge’s recommendations to punish Frank for revealing his beliefs.
  • December 2025: Frank was ordered to pay the $89,636.43 bill of costs.
  • April 2026: ADF, alongside local attorney Matthew Wand, filed their opening brief appealing the Board’s decision to the Court of Appeals for the State of Oregon.