








































Graduate Student Journal of Psychology                                                                             Copyright 2005 by the Department of Counseling & Clinical Psychology 


Graduate Student Journal of Psychology                                                                             Copyright 2006 by the Department of Counseling & Clinical Psychology  
2006, Vol. 8                                                                                                                          Teachers College, Columbia University                          ISSN 1088-4661 
 
 
 

Sudden Unexpected Death of the Therapist: 
Reconciling Ethical and Clinical Concerns for Providing Continuing Care 

 
Melanie Merola O’Donnell 

Antioch New England Graduate School 
 

The sudden unexpected death of a therapist is examined with consideration given to ethical, clini-
cal, and legal implications for therapists in planning for the possibility of their deaths. A vignette 
is provided for illustration. The Code of Ethics (APA, 2002) is reviewed for relevant guidance, 
and the professional literature is summarized. It is concluded that while the Code of Ethics only 
dictates minimal activity in preparation for death, the professional literature makes a strong case 
for more elaborate planning in order to reduce harm to clients. A summary of recommendations 
for therapists in planning for their sudden unexpected deaths is provided. 

 
 

As usual, Dr. Molinari arises at 5:30 a.m. to start her 
day. It is another full day. She will attend her morning ex-
ercise class, return home to eat breakfast and shower, and 
head to the office for her prompt 8:00 a.m. arrival. On her 
professional agenda for the day are three individual psycho-
therapy sessions, one couples session, one hour of supervi-
sion with a student at the local graduate school, and a meet-
ing with colleagues about a program that is being developed 
for at-risk youth. She is prepared for each session but her 
mind is focused on a former client who terminated several 
years ago. This client is on her mind because it is the tenth 
anniversary of the day that the client quit drinking. She has 
been sober since. Dr. Molinari saw this client in treatment 
intermittently for approximately six years, and she knows 
that this is a day of celebration for that person. As Dr. 
Molinari leaves her neighborhood in the pre-dawn darkness, 
her car is struck by an eighteen-wheeler and she is killed 
instantly. Within a few hours Dr. Molinari’s body has been 
identified and her family and one colleague have been noti-
fied. If you were the colleague of Dr. Molinari that was 
notified of her death, how would you proceed with the dis-
pensing of her professional responsibilities? What issues 
might arise as Dr. Molinari’s practice is terminated? 

The case described above forces consideration of the 
ethical, clinical, and legal obligations that therapists have in 
making plans for their own unexpected deaths. Recent data 
suggest that such planning is not common. A survey con-
ducted with therapists involved in the resolution of profes-
sional responsibilities for deceased therapists indicated that 
90% of the deceased therapists had no preplanned 

 
Less than two weeks after submitting this article for publication, 
the author died in an automobile accident. She was 33 years old. 
Her husband, George O’Donnell, completed the edits for this arti-
cle prior to publication.

Correspondence concerning this article should be addressed 
to George O'Donnell, 55 Birch Street, Saratoga Springs, NY, 
12866; email: geodonnell@yahoo.com. 

procedure to assist their clients with the transition following 
their deaths, and that 94% of clients were not provided with 
referrals (Garcia-Lawson, Lane, & Koetting, 2000). Such 
statistics reinforce the need for clarity on the ethical respon-
sibilities of therapists in planning for their clients should the 
therapists die unexpectedly. 
 

Culling the Ethics Code 
 

There are few ethics codes proposed by the American 
Psychological Association (APA) that speak directly to the 
question at hand. Standard 3.12, Interruption of Psycho-
logical Services states: 

Unless otherwise covered by contract, psychologists 
make reasonable efforts to plan for facilitating services 
in the event that psychological services are interrupted 
by factors such as the psychologist’s illness, death, un-
availability, relocation, or retirement or by the cli-
ent’s/patient’s relocation or financial limitations. 
(APA, 2002, p. 1066) 

Fisher (2003) interprets this standard to mean that a trusted 
colleague should be prepared to contact clients in the event 
of unplanned interruptions and that a therapist’s “reason-
able efforts” reflect the reality of the unpredictable nature 
of life. 

Standard 6.02c, Maintenance, Dissemination, and Dis-
posal of Confidential Records of Professional and Scientific 
Work states: “Psychologists make plans in advance to facili-
tate the appropriate transfer and to protect the confidential-
ity of records and data in the event of psychologists’ with-
drawal from positions or practice” (APA, 2002, p. 1067). In 
Fisher’s (2003) clarifying comments, the psychologist’s 
death is specifically mentioned as one such reason for with-
drawal, and the methods of record transfer are identified as 
in person, by mail, by fax, through the Internet, or through 
private company networks, as long as confidentiality is 
maintained. 

45 



O’DONNELL 
 

46 

Aside from these two specific references to death, 
therapists can only speculate as to whether or not other 
standards apply in the case of the sudden unexpected death 
of the therapist. For example, does Standard 3.04, Avoiding 
Harm (APA, 2002, p. 1065) apply? It indicates that psy-
chologists take reasonable steps to avoid harm to clients. Is 
harm caused to a client when his or her therapist dies unex-
pectedly, and no plan is in place to continue care? Does 
Standard 10.09, Interruption of Therapy (APA, 2002, p. 
1073) apply? It indicates that psychologists at the outset of 
employment establish a plan for continuity of care in the 
event of employment termination. Does Standard 10.10c, 
Terminating Therapy (APA, 2002, p. 1073) apply? It indi-
cates that psychologists provide pretermination counseling 
and suggest alternative service providers to clients prior to 
termination. Should therapists at the outset of therapy dis-
cuss the possibility of their untimely death and provide 
emergency referrals at that time? 

As if these questions were not enough to consider, 
some standards complicate the handling of notification and 
transitional services for clients. Most notably, psychologists 
are bound by Standard 4.01, Maintaining Confidentiality 
(APA, 2002, p. 1066). Yet the allowances for breaking con-
fidentiality do include circumstances in which the therapist 
has died unexpectedly and another person contacts the cli-
ent for notification of the death or to offer transitional ser-
vices.  

In summary, the ethics code indicates that psycholo-
gists have a responsibility to plan for their unexpected 
deaths to the extent of facilitating transitional services. 
These services can include identifying a colleague to notify 
clients of the therapist’s death and to have a plan in place 
for the confidential transfer of client files. The answers to 
other questions, such as whether or not harm is done or a 
breach of confidentiality has occurred if plans for continued 
care are not implemented, are unclear. Further, the interac-
tion of these responsibilities with others, such as maintain-
ing confidentiality, is left to interpretation. A look to the 
literature may be useful for further clarification. 

 
Culling the Literature 

 
In turning to the literature on the handling of profes-

sional responsibilities following the sudden unexpected 
death of a therapist, an interesting point emerges. Several 
authors have noted that there is very little in the literature 
about this topic (Beder, 2003; Cohen, 1983; Garcia-Lawson 
et al., 2000). Garcia-Lawson et al. suggest that this silence 
may be tied to a broader discomfort with the topic of death 
and dying, and specifically resistance to considering one’s 
own death. Cohen echoes that speculation, and adds that 
other factors specific to the psychotherapeutic setting may 
influence such silence. For example, Cohen argues that the 
practice of psychotherapy can be isolating and can lead 
therapists to experience a sense of separateness from others. 
Contemplation of issues around death may exacerbate this 
experience and raise anxiety. Further, Cohen argues that 

psychotherapy often carries with it a sense of timelessness 
that may blur the realities of life, such as the inescapability 
of death. Whatever the reason, the dearth of writing on the 
topic is notable. This is especially true when considering 
the implications drawn from reviewing the existing litera-
ture. 
 
On Interruption of Services 
 

Most of the literature on handling the interruption of 
services following a therapist’s death implies that he or she 
has a clinical obligation—above and beyond the ethical 
obligation—to identify a colleague who will notify clients 
of the death. The literature that refers specifically to the 
handling of notification raises several points. First is the 
issue of how a client is informed of the death. The founda-
tion demonstrating the relevance of this issue comes from 
studies that suggest that the psychological impact on the 
client of the unexpected death of his or her therapist is in-
fluenced by the death notification received (Beder, 2003; 
Tallmer, 1989). Garcia-Lawson et al. (2000) found that 
notification has been received by clients via widely differ-
ent sources, including from colleagues of the deceased 
therapist, from the therapist’s spouse, from their own 
friends, from a member of their therapy group, by being 
present at the time of death, and by reading an obituary. 
They further note that many clients reported being confused 
about who, if anyone, was responsible for handling the in-
formation.  

Several authors have suggested methods for a more ap-
propriate handling of the death notification. Garcia-Lawson 
et al. (2000) suggest (a) changing the therapist’s answering 
machine message immediately to note the cancellation of 
all future appointments; (b) posting a note on the therapist’s 
door noting the cancellation of all future appointments and 
providing a number to call to get further information; and, 
(c) providing the doorman and elevator operator (if they 
exist) with similar information. Cohen (1983) suggests that 
a colleague of the deceased therapist maintain phone num-
bers for the therapist’s clients along with instructions on 
what to tell them about the death. Others suggest that the 
list need not be kept by a colleague but in an accessible 
place of which colleagues are aware (Bram, 1995). If thera-
pists rely on an appointment book for listing clients, and 
that book holds initials only (in an attempt to maintain con-
fidentiality), a separate list would need to be located in an 
accessible location so that colleagues have the full names of 
the individuals that they will need to contact (Freedman, 
1990).  

A second related issue that is addressed in the literature 
has to do with what, if any, services should be provided to 
clients upon learning that their therapist has died unexpect-
edly. Bram (1995) argues that all therapists should ensure 
that clients will be taken care of in the event of their thera-
pist’s unexpected death. Garcia-Lawson et al. (2000) sug-
gest that the care come in the form of providing options to 
the client, such as entering treatment immediately with an-



UNEXPECTED DEATH OF THERAPIST 
 

47 

other therapist to process grief; waiting a time period and 
returning to therapy with a new therapist; or, not attending 
therapy again in the foreseeable future. Garcia-Lawson et 
al. argue that there is often a need to share and process reac-
tions to loss, and clients should be offered the option to do 
so with another therapist. Cohen (1983) takes this argument 
further, stating that therapists should maintain clinical di-
rections for each client so that the therapists’ colleagues 
have some information on how to proceed. It is further 
noted that these directions should be provided directly to 
the colleagues, rather than be recorded in a will that may 
not be read for some time following the death. Others have 
echoed this suggestion (Freedman, 1990). 

In the study conducted by Garcia-Lawson et al. (2000), 
56% of clients of deceased therapists were offered a consul-
tation session within one month of the deaths and most ac-
cepted the invitation. In addition, some authors have cited 
the offer of a referral, or lack thereof, as an influencing fac-
tor in the psychological impact of the therapist’s death on 
the client (Tallmer, 1989). These findings suggest that the 
offering of some form of intervention is useful. Should such 
an intervention be offered, several authors have suggested 
that therapists to whom clients are referred be educated on 
special issues that may be present for these clients. This 
may include education on clients initially being difficult to 
treat and having mixed transferences (Garcia-Lawson et al., 
2000); the loss associated with losing the unique role of a 
therapist in a client’s life (Beder, 2003); and, a client’s feel-
ings of disloyalty to the deceased therapist (Garcia-Lawson 
& Lane, 1997). Though not mentioned in the literature, it 
also seems relevant to consider any impediments to provid-
ing unbiased care that may arise should the client be re-
ferred to a therapist who is a close friend of the deceased 
therapist, and therefore grieving as well. 

 
On Disposing of Confidential Records 
 

The study by Garcia-Lawson et al. (2000) indicated 
that 90% of the clients from the sample were not provided 
their records following the deaths of their therapists. De-
spite this, the literature seems to indicate that it is good 
practice to offer clients their records at the time of the death 
notification (McGee, 2003). Others indicated that files be 
protected by a colleague of the deceased therapist until a 
future date when they could be transferred to a referring 
therapist or destroyed (Cohen, 1983; Garcia-Lawson et al., 
2000). 
 
On Avoiding Harm 
 

As stated previously, the ethics code is unclear as to 
whether or not a psychologist is considered to be causing 
harm if he or she does not make plans for clients in the 
event of the psychologist’s sudden unexpected death. The 
professional literature, however, makes a strong statement 
about the clinical obligation to do so. For example, Beder 

(2003) notes that positive treatment outcomes may be 
eliminated as a result of a poor termination. Cohen (1983) 
agrees, suggesting that such an occurrence can be psycho-
logically devastating to the client. These premises suggest a 
clear tie to causing harm. Several authors have reviewed the 
common client reactions to the unexpected termination of 
therapy. These include intense grief reactions with feelings 
of anger, despair, depersonalization, and somatization (Gar-
cia-Lawson et al., 2000); rage, feelings of abandonment, 
and betrayal of trust (Beder, 2003); guilt, disappointment, 
and bitterness (Garcia-Lawson & Lane, 1997); loneliness 
(Levin, 1998); and, the retriggering of previous experiences 
of separation (Freedman, 1990; Levin, 1998). In addition, 
some positive reactions were found, such as learning to 
cope better with tragedy, separation, and loss (Garcia-
Lawson et al., 2000), and making a break from therapy that 
was otherwise difficult for the client to do on his or her 
volition (Garcia-Lawson & Lane, 1997).  

Speculation on the reasons for such impact has focused 
predominately on the unique nature of the therapeutic rela-
tionship (Cohen, 1983; Garcia-Lawson & Lane, 1997; Gar-
cia-Lawson et al., 2000). In addition it has been noted that 
the sudden unexpected termination of therapy robs the cli-
ent of a termination phase wherein the object loss may be 
confronted directly (Garcia-Lawson et al., 2000). As such, 
several authors imply that there is a clinical and ethical ob-
ligation to plan for sudden unexpected death as one way of 
avoiding harm (Cohen, 1983; Freedman, 1990; Garcia-
Lawson, et al., 2000; Koocher, 2003; McGee, 2003). It is 
worth noting that most of the literature on this issue comes 
from practitioners of psychoanalysis or psychoanalytic 
therapy. As Bram (1995) notes, this may relate to several 
factors specific to psychoanalytic therapy, including (a) the 
focus on the relationship between client and therapist; (b) 
the tendency towards longer treatment periods; and, (c) the 
emphasis on issues of separation and loss.  
 
On Talking About Death in Advance 
 

One of the areas of most disagreement surrounds the 
topic of whether or not clients should be confronted with 
the possibility of the sudden unexpected death of the thera-
pist during therapy. Some authors suggest that preplanned 
instructions to assist the client in the event of an unexpected 
death be included in the framework at the start of therapy 
(Garcia-Lawson, et al., 2000; McGee, 2003), such that ter-
mination begins with the first session (Garcia-Lawson & 
Lane, 1997). Other authors suggest that nothing be said at 
the start of therapy, though plans should be in place in case 
death occurs (Cohen, 1983; Freedman, 1990). Cohen sug-
gests that information about the therapist’s possible death at 
the start of therapy could hinder the client in his or her 
treatment. The lack of clarity on the topic has led to the 
suggestion that further data be collected to determine the 
most appropriate way of handling such conversations, and 
the level of detail to discuss (Abend, 1982).  

 



O’DONNELL 
 

48 

On Confidentiality 
 

The issue of handling confidentiality while simultane-
ously trying to avoid harm is murky at best. Cohen (1983) 
is the most extensive in attention to this issue. He acknowl-
edges that preparing a client list with treatment recommen-
dations is a breach of confidentiality. The alternatives to 
handling the situation which do not involve such a breach 
are listed as (a) choosing to do nothing, (b) leaving a note 
on the door, and (c) asking advance permission to break 
confidentiality in the event that death occurs. Cohen argues 
that each of these situations would be highly anxiety-
provoking for the client, possibly harmful, and therefore 
inappropriate. In addition, Cohen argues that the ethical 
responsibility of therapists to clients in the unusual event of 
death overrides the issue of breaking confidentiality. In 
interviewing several clients who had experienced the death 
of their therapists, Freedman (1990) reports that all were 
accepting of the breach in confidentiality given the circum-
stances. This provides support for Cohen’s conclusion. Still, 
the issue remains that what seems to be ethically and clini-
cally appropriate regarding preparing for a therapist’s death 
is ethically at odds with maintaining confidentiality. As 
Cohen states, all options should be considered by the thera-
pist, even those that he or she has deemed inappropriate. 
 
Other Issues 
 

The ethical issues reviewed above relate to the stan-
dards in the ethics code that appear relevant to the scenario 
of a therapist’s unexpected death. The literature raises sev-
eral additional points. These points will be considered 
briefly below. First is the important issue of ensuring that 
therapists consult state law when considering how to handle 
the possibility of unexpected death. As McGee (2003) 
notes, state jurisdictions typically have laws regarding in-
formed consent, confidentiality, the transfer of records, and 
the amount of time that records are retained. Therapists 
should be considering all aspects of the issue of possible 
sudden unexpected death. This includes ethical, clinical, 
and legal considerations. A related point, made by Cohen 
(1983), is that therapists should include legal counsel in the 
planning and preparation for their deaths and the execution 
of wishes after their death. This helps ensure that both the 
therapists’ and their clients’ interests are protected. 

Second, it has been suggested that, rather than simply 
providing referrals to clients or a list of names and treat-
ment recommendations to colleagues, therapists actually 
appoint a colleague as a professional executor to handle all 
aspects of their professional responsibilities (Cohen, 1983; 
McGee, 2003). This would enable better coordination and 
ensure that nothing is overlooked (e.g., logistics like bill-
ing). Third, Freedman (1990) points out that a therapist 
should maintain notes with the possibility of his or her 
death in mind. In other words, ensure that what is written is 
clearly understandable to others—including the client—

without the therapist’s verbal input as the therapist may not 
be around to provide it.  

Fourth is the issue of whether or not former clients 
should be notified when a therapist dies. Cohen (1983) sug-
gests that this determination be part of the advanced plan-
ning done by therapists in preparation for death. McGee 
(2003) provides suggested guidelines for when to contact 
former clients of a therapist’s death. These include contact-
ing (a) individuals who were clients within the past five 
years, (b) individuals who had especially strong transfer-
ence feelings, (c) individuals who participated in several 
periods of therapy, and (d) individuals who participated in 
long-term therapy. 

Finally, several authors suggest advance consideration 
of whether or not clients will be invited to participate in 
funeral services or other rituals for the deceased therapist 
(Beder, 2003; Garcia-Lawson et al., 2000). In the study 
conducted by Garcia-Lawson et al., 81% of clients partici-
pated in either a funeral or memorial service for their de-
ceased therapists. Tallmer (1989) reviewed anecdotal evi-
dence that found that such participation was helpful for 
some clients and not for others. If the therapist is comfort-
able with the idea of their clients participating in death ritu-
als, it may be that providing the option to each is most 
beneficial. Regardless, this decision is best made in advance 
by the therapist and not left to be sorted by their colleagues. 
 

Conclusion 
 
The Code of Ethics (APA, 2002) provides limited 

guidance to psychologists looking to address the possibility 
of their sudden unexpected death. At a minimum it seems to 
suggest that psychologists select a colleague to notify their 
clients and plan for the confidential handling of records 
should such a tragedy occur. It is less clear what provisions 
are needed to ensure that client harm is avoided and on how 
to handle client notification without breaching confidential-
ity. In addition, it is less clear whether or not some form of 
service should be offered in order to promote continuity of 
client care. 

Suggestions on these topics and others can be found in 
the professional literature, which touches on the ethical, 
clinical, and legal considerations in preparing for an unex-
pected death. The most extensive suggestion entails the 
designation of a professional executor to handle all aspects 
of the dismantling of the therapist’s practice. This would 
include the notification of clients, the offering of continuing 
care, the handling of office logistics such as billing and 
changing answering machine messages, the handling of 
records, the oversight of confidentiality, and contact with 
legal counsel. 

In order to do so, therapists must do extensive plan-
ning. They must create client lists that are accessible, un-
derstandable, and continually updated to include contact 
information and treatment recommendations. Therapists 
must keep their death in mind while recording notes such 
that the notes will be understandable to others in their ab-



UNEXPECTED DEATH OF THERAPIST 
 

49 

sence. They must give instructions on what to tell clients; 
how to handle former clients; whether or not to include 
clients in death rituals; whether or not the possibility of 
death has been addressed in advance; and to whom clients 
should be referred, keeping in mind how referring therapists 
will be coping with the therapist’s death. They must indi-
cate their desire for the types of services offered to clients 
(e.g., grief counseling, therapy referral, consultation). They 
must indicate how they have accounted for confidentiality 
issues and provide instructions on the handling of records 
including related limitations of state laws. They must iden-
tify legal counsel. Finally, they should educate the executor 
as to the process and special issues that might arise, such as 
the difficulty that referring therapists may experience in 
taking on clients of a deceased therapist. Ragusea (2002) 
has proposed a sample of a Professional Living Will, which 
contains much of this information.  

If therapists have not considered their feelings about 
death, and specifically their own deaths, it is suggested that 
they force themselves to ponder the topic (Garcia-Lawson 
et al., 2000). The dearth of literature on the topic suggests 
that many therapists have not done so. Yet if a therapist has 
not thought through the impact of his or her death on cli-
ents, it is unlikely that his or her clients’ best interests are 
being served. 

 
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	Culling the Literature

