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Journal of Counseling Psychology

1983, Vol. 30, No. 2,245-251


Copyright 1983 by the American ! igical Association, Inc.
i7/83/3002-0245$00.75
Breach of Confidentiality and
Perceived Trustworthiness of Counselors
Thomas V. Merluzzi
University of Notre Dame
Cheryl S. Brischetto
Oregon Health Sciences University
This study investigated the impact of breaching confidentiality on perceptions
of counselor trustworthiness. Subjects heard audiotaped counselor-client in-
teractions that culminated in a decision by the counselor to breach or maintain
confidentiality. In a control condition no confidentiality manipulation was
presented. The degree of seriousness of the client's problem was manipulated
in addition to the level of counselor experience, type of presenting problem,
and counselor. Two hundred male undergraduates were randomly assigned
to one of 48 cells defined by a 3 (confidentiality: confidential, nonconfidential
or control) X 2 (problem seriousness: highly or moderately serious) X 2
(counselor experience: expert or nonexpert) X 2 (presenting problem: sui-
cide or drug abuse) X 2 (counselor: A or B) between-subjects factorial design.
Among other measures subjects rated counselors on trustworthiness. A Con-
fidentiality X Problem Seriousness Interaction indicated that with highly seri-
ous client problems breaching confidentiality was associated with significantly
lower trustworthiness ratings compared to all other conditions. The implica-
tions of these results and other findings are discussed.
In his initial conceptualization of coun-
seling as an interpersonal influence process,
Strong (1968) suggested two consequences
of trustworthy behavior; first, it would en-
hance the client's divulgence of personally
damaging material, and second, it would
enhance the extent to which the counselor
can influence the client. Further, Strong
indicated that the counselor can be perceived
as trustworthy by "paying close attention to
the client's statements and other behavior,
by communicating concern for the client's
welfare, by avoiding statements indicating
exhibitionism or perverted curiosity, and by
assuring confidentiality of all transactions"
(Strong, 1968, p. 222; emphasis added).
Two recent reviews of the literature have
emphasized the need for research on trust-
worthiness in counseling relationships,
(Corrigan, Dell, Lewis, & Schmidt, 1980;
Heppner & Dixon, 1981). In the studies
The authors wish to thank Mark Rodrigues and Stan
Hoffman for portraying the counselors. Also, we would
like to acknowledge Morgan Griffith's invaluable con-
tribution to data collection and reduction in this
study.
Requests for reprints should be sent to Thomas V.
Merluzzi, Department of Psychology, University of
Notre Dame, Notre Dame, Indiana, 46556.
reviewed by Corrigan et al. (1980) and
Heppner and Dixon (1981), and in subse-
quent studies (LaFromboise & Dixon, 1981;
Rothmeier & Dixon, 1980), a number of
verbal and nonverbal cues were used to dis-
tinguish trustworthy and untrustworthy
counselor behaviors. Although these stud-
ies, in general, did establish a number of
behaviors that were indicative of untrust-
worthy counselor demeanor, the behaviors
used to create role descriptions of untrust-
worthy counselors were numerous and ex-
treme and not likely to represent an actual
counseling situation. In contrast, during
actual clinical practice, counselors who may
be empathic and helpful often struggle with
the problem of confidentiality and its effect
on trustworthiness in the counseling rela-
tionship. In addition, the most recently
promulgated APA Ethical Principles for
Psychologists emphasize thai exceptions to
confidentiality must be made if clients
present danger to themselves or others
(American Psychological Association, 1981).
In some instances the judgment to breach
confidentiality is clear, evident, and neces-
sary for the welfare of the clientin other
instances it is more equivocal. However,
overall, the Principles do not provide the
psychologist with a clear set of guidelines
245
246 THOMAS V. MERLUZZI AND CHERYL S. BRISCHETTO
concerning when information can be re-
leased.
Thus, whereas the research on trustwor-
thiness has focused on a number of extreme
behaviors and situations to define "un-
trustworthy counselor behavior," breach of
confidentiality (and limits on confidential-
ity) may actually occur more often in more
typical situations, in which the counselor is
generally acting in an empathic, helpful, and
trustworthy manner. In those situations,
breaching confidentiality may be a difficult
decision for the therapist. In fact, the APA
Ethical Principles suggest that review of the
case with professional colleagues and serious
deliberation are in order in cases in which
breach of confidentiality is considered.
This study attempted to investigate the
impact of breaching confidentiality on per-
ceived trustworthiness of counselors con-
ducting initial interviews. The decision, on
the part of the counselor, to maintain or
breach confidentiality was presented as a
serious issue that required much delibera-
tion. Moreover, the audiotaped interchange
between the counselor and client presented
the counselor as an empathic, caring person.
In addition, in order to determine if the de-
gree of experience of the counselor would
affect the perceptions of trustworthiness,
counselors were presented as either "expert"
or "nonexpert." Finally, one might assume
that breaching confidentiality would occur
more frequently in situations in which the
client's problems were very serious. For the
sake of comparison the level of seriousness
of the client's problem was manipulated to
study the effects of breaching confidentiality
on trustworthiness as a function of the seri-
ousness of the presenting problem.
Method
Subjects and Design
Subjects were 200 male undergraduates from a pri-
vate midwestern university (ages 18-21) who were en-
rolled in Introduction to Psychology and received course
credit for their participation in the experiment.
Subjects were run prior to the section of the course that
covers therapy. Therefore, they were not all system-
atically exposed to the practice of confidentiality. In
addition, because they were mostly freshman and
sophomores, they had not taken any additional course
work in psychology that would have sensitized them to
the issues of confidentiality. Finally, although some
may have received previous counseling services, fresh-
man and sophomores, are the least served by the uni-
versity counseling center. Therefore, the population
in this study was considered to be no more sophisticated
vis-a-vis confidentiality than any other sample in that
age group. Subjects were randomly assigned to one of
48 conditions with no less than four subjects in each
condition. The study was a 3 (confidentiality: confi-
dential, nonconfidential, or control) X 2 (problem se-
riousness: highly serious or moderately serious) X 2
(counselor experience: expert or nonexpert) X 2 (pre-
senting problem: suicide or drug abuse) X 2 (counselor:
Counselor A or Counselor B) between-subjects de-
sign.
Independent Variables
Confidentiality. Following an audiotaped dialogue
between a client and counselor, the counselor was por-
trayed as being alone in his office and thinking aloud
about the interview. The following statement was then
spoken by the counselor: "This person has a problem;
he seems embarassed about it and was hesitant to come
for help." Then, one of two confidentiality manipula-
tions was presented as the conclusion to the counselor's
thoughts. In the nonconfidential condition the
counselor said "I think it's important that I notify this
person's family about this situation." In the confi-
dential condition the counselor concluded by saying "I
think it's important that I not mention this situation to
this person's family." For the control condition, after
the dialogue between the client and counselor was
completed, there was no statement made by the coun
:
selor.
Problem seriousness and type of presenting problem.
Individual scripts
1
of clients-counselor interactions were
developed for each of two presenting problems (suicide
and drug abuse) and two levels of problem seriousness
(highly serious and moderately serious). The dialogues
in each of the scripts were kept as similar as possible
except for variations that reflected the different pre-
senting problems and levels of problem seriousness.
Thus, a script presenting a moderately serious problem
was developed and adapted to reflect concerns related
to suicide and drug abuse. That script was also adapted
to present a serious suicide or drug abuse problem.
Two second-year male doctoral students in counsel-
ing psychology portrayed the counselors, and a second-
year law student portrayed the client on the audiotapes.
They were all given the scripts in advance and practiced
extensively prior to the taping session. With the con-
fidentiality manipulations deleted, the audiotapes were
subjected to pilot testing to determine if any differences
occurred between counselors. In the pilot study 64
undergraduates, who received experimental credit, were
randomly assigned to one of 8 conditions defined by two
levels of problem seriousness (serious vs. nonserious),
two presenting problems (suicide vs. drug abuse) and
two counselors (A vs. B). Thus, the pilot was a 2 X 2 X
2 between-subjects factorial design. The Expertness,
Attractiveness, and Trustworthiness scales of the
Counselor Rating Form (see Dependent Measures
1
Copies of the counselor-client interactions are
available from the first author.
CONFIDENTIALITY AND TRUSTWORTHINESS 247
section) yielded no main effects or interactions.
Therefore, the counselors' behavior in all the tapes was
comparable and did not vary as a function of presenting
problem or problem seriousness.
Experience level. The level of experience of the
counselor was manipulated by written introductions.
Prior to listening to the audiotaped interview described
above, subjects read a description (reproduced below)
of the counselor that portrayed him as either expert or
nonexpert. <
Expert Introduction
The counselor you will be hearing has received his
PhD in counseling psychology. He has had exten-
sive training and experience as a professional coun-
selor and has published a book, Innovative Tech-
niques in Counseling. He is presently on the staff
of a university counseling center.
Nonexpert Introduction
The counselor you will be hearing is currently a
first-year trainee in a doctoral program in counsel-
ing psychology. He received his BA in psychology
a year ago. He has recently completed a course in
counseling theory and practice.
Procedure
Prior to hearing the audiotape, subjects were in-
formed that one purpose of the experiment was to assess
the decision making abilities of counselors. They were
also told that the dialogue they were about to hear was
taken from an actual counseling session in the university
counseling center. The subjects were encouraged to try
to assume the client's role and to see the problem from
the client's perspective. Next, they read the written
introduction that described the counselor as either ex-
pert or nonexpert. Then, depending on the condition
to which the subjects were assigned they read one of the
four following descriptions of the client.
Serious Suicide Problem
You are a 21-year-old male who has come to the uni-
versity counseling center because you have been
very depressed. You have, in the past, made re-
peated attempts to take your life and you were also
hospitalized for severe depression. You find your-
self now, again, in a similar-situation with similar
feelings. You cry a lot and are seriously thinking of
taking your life.
Serious Drug Problem
You are a 21-year-old male who has come to the uni-
versity counseling center because you believe that
you are a heroin addict and you are desperate. You
are physically and mentally a wreck. Getting the
next fix is what's on your mind. You are into steal-
ing to finance your habit. Recently, you had a close
call with death from taking some bad stuff someone
sold you on campus. You have been hallucinating a
lot. You almost killed yourself and someone else
while driving your car.
Moderately Serious Suicide Problem
You are a 21-year-old male who has come to the uni-
versity counseling center because you have been
feeing a little blue lately. You feel like nobody ap-
preciates you; neither friends nor family. Some-
times when things are going well you feel like life is
okay. However, there are those other times when
, you feel like ending it all.
Moderately Serious Drug Problem
You are a 21-year-old male who has come to the uni-
versity counseling center because you are feeling
kind of out of it. You have been smoking grass fre-
quently and have been feeling kind of indifferent
toward everything and everyone.
In the conditions in which confidentiality was ma-
nipulated the client descriptions for all problems in-
cluded the following concluding paragraph:
You have resisted coming to talk to anyone because
you are ashamed and don't want others to know
things are bothering you. Imagine yourself seeing a
counselor and the following dialogue occurring be-
tween the two of you. After the dialogue there will
be a pause on the tape. The end of the pause will
signify the end of the interview segment and the
counselor will then be alone in his office thinking
aloud about something directly related to the inter-
view.
This last paragraph was altered in the control con-
dition. The following statement replaced the last
sentence: "The end of this pause will signify the end of
the interview." After reading one of these client de-
scriptions the appropriate audiotaped interview was
played twice for the subjects so that they might adopt
more effectively the client's perspective and hear the
confidentiality manipulation. After listening to the
counselor-client interaction they completed several
rating forms and were debriefed and dismissed.
Dependent Measures
The Counselor Rating Form (CRF; Barak & La-
Crosse, 1975) was used to measure the subjects' per-
ceptions of trustworthiness. The CRF contains 36 pairs
of bipolar adjectives that assess the dimension of
counselor expertness, social attractiveness and trust-
worthiness. The authors report split-half reliabilities
of .87.85, and .90 for the three dimensions, respectively
(LaCrosse & Barak, 1976). Although the trustworthi-
ness scale was of primary interest, the expertness and
attractiveness scales were also reported.
Subjects also completed several ancillary measures
that pertained to the counseling interview. Using a 1-7
scale they rated two questions in each of the following
areas: (a) How well did the counselor understand the
client's problem? (b) Would the outcome of counseling
be positive or negative? and (c) Would you refer an ac-
quaintance or a close friend to the counselor? The sum
of the ratings of each of the two questions in each area
was used in the analysis. Additional questions assessed
whether subjects felt that confidentiality should be
maintained and to whom, if anyone, information should
or could be divulged. Finally, questionnaire items were
included to determine if the confidentiality and problem
seriousness manipulations were perceived as intended.
Subjects were asked to rate on 7-point scales (a) how
confidential or nonconfidential was the counselor and
(b) how serious was the client's problem.
248 THOMAS V. MERLUZZI AND CHERYL S. BRISCHETTO
Results
Manipulation Check Measures
An Analysis of Variance (ANOVA) on the
manipulation check measures revealed sig-
nificant main effects for subjects' ratings of
how confidential the counselor was, F(2,153)
= 168.15, p < .001, and how serious the
client's problem was, F(l, 153) = 63.30, p <
.001. Thus, the manipulations of confi-
dentiality and seriousness were perceived by
subjects as intended. The expertness scale
of the CRF was used to assess the impact of
the experience level manipulations. The
analysis of expertness ratings as a function
of experience level revealed no significant
differences, F(l, 153) = 2.37, p ~ .125, be-
tween high experience level counselors (M
= 47.94) and low experience level counselors
(M = 44.98). Thus, the manipulation of
experience level either was not well detected
by the subjects or riot a critical variable in
the perception of subjects.
Counselor and Presenting Problem
Based on pilot testing it was anticipated
that the effects of counselor and presenting
problem would not be significant. However,
Counselor B was seen as more expert (M =
48.43) and more attractive (M = 48.90) than
Counselor A (M = 43.49; M = 45.05). Also,
when counselors discussed suicide problems
they were seen as more attractive (M =
49.00) than when discussing drug problems
(M = 44.99). As a result of these findings,
the remaining analyses were collapsed across
counselor and presenting problem for
trustworthiness while the full five-factor
design was retained for expertness and at-
tractiveness. Because the trustworthiness
results were central to the study, the coun-
selor differences noted above did not detract
from the main thrust of the study.
Trustworthiness and Attractiveness
An ANOVA of trustworthiness ratings re-
vealed a significant main effect of confi-
dentiality on trustworthiness, F(2, 153) =
10.87, p < .001. In addition, significant
Problem Seriousness X Confidentiality In-
teraction for trustworthiness, F(2, 153) =
4.70, p < .01, was obtained (Table 1).
A close inspection of Table 1 reveals that
the main effect of trustworthiness was a
function of one deviant group; the high-
problem-seriousness-nonconfidential con-
dition. Therefore, the interaction was seen
as the more appropriate level at which to
interpret the findings. Essentially, when
counselors decided to breach confidentiality
with clients who had very serious presenting
problems they were seen at least trustwor-
thy. Although the attractiveness scale of the
CRF was not central to the study, inspection
of Table 1 reveals that the attractiveness
ratings paralleled, to some extent, the
trustworthiness ratings. However, the
scores were less extreme and differences less
pronounced. The breaching of confidenti-
ality with serious client problems did not
significantly diminish the counselor's at-
tractiveness as it did with trustworthiness.
However, maintaining confidentiality did
enhance attractiveness with clients who were
experiencing highly serious problems. As in
previous studies, the correlations among the
scales of the CRF were high. The correla-
Table 1
Means and Standard Deviations for
Trustworthiness and Attractiveness Scores as
a Function of Confidentiality Condition and
Level of Problem Seriousness
Problem seriousness
Experimental
condition
High Moderate
M SD M SD
Trustworthiness
Confidential
Nonconfidential
Control
60.37
b
10.85 55.30
b
12.18
43.88" 14.97 52.09
b
11.59
54.35
b
13.26 54.58
b
11.03
Attractiveness
Confidential 53.35
b
10.47 45.66" 14.01
Nonconfidential 42.38" 13.53 45.47" 12.86
Control 48.12"
b
14.39 47.18"
b
11.80
Note. A higher score indicates greater perceived
trustworthiness or attractiveness. Different letters
indicate that means were significantly different.
Trustworthiness scores were different at p < .01,
whereas those for attractiveness were different at
p < .05.
CONFIDENTIALITY AND TRUSTWORTHINESS 249
Table 2
Means and Standard Deviations for the Confidentiality Conditions on the Measures of
Predicted Outcome, Endorsement for Referral and Counselors' Understanding of the Client's
Problem
Measure
Outcome Referral Understanding
Experimental condition M SD M SD M SD
Confidentiality
Nonconfidentiality
Control
7.28
b
5.42
7,06
b
3,35
2.68
2.96
8.75
b
6.33"
9.07
b
5.70
4.10
5.03
8.96
b
6.53"
8.39
b
3.42
3.10
2.95
Note. A higher score indicates more chance of favorable outcome, greater likelihood of referring a friend or more
feeling of being understood. Different letters indicate means significantly different at p < .05.
tion between the trustworthiness and ex-
pertness scale was .74; trustworthiness and
attractiveness, .76; expertness and attrac-
tiveness, .72.
Ancillary Measures
Analyses (ANOVA) revealed significant
main effects of confidentiality for the coun-
selors' degree of understanding of the client,
F(2,153) = 9.84, p < .001, expected outcome,
F(2,153) = 7.23, p < .001, and endorsement
for referral, F(2,153) = 5.73, p < .004. Post
hoc analysis (Tukey HSD; Kirk, 1968) indi-
cated that counselors in the nonconfidential
condition were significantly lower than
counselors in the confidential and control
conditions across all three measures (Ta-
ble 2).
TableS
Frequency of Yes and No Responses to the
Question of Whether Confidentiality Should
be Maintained
Condition
Non-
Response Confidential confidential Control
Highly serious problems
Yes
No
15
17
15
19
20
14
Moderately serious problems
Yes
No
19
17
14
18
18
24
Finally, analyses were performed on the
following questions: (a) Do you think the
counselor should tell someone about this
(problem)yes or no? (b) If yes, whom do
you think he should tellparents, police,
colleague, supervisor, head of dorm, or
friend? For the first question two two-way
tables were constructed, one for highly seri-
ous and one for moderately serious client
problems. In each table the frequency of yes
and no responses was crossed with the three
confidentiality conditions. There were no
significant effects in responses for highly
serious problems, but there was a significant
effect x
2
(2) = 6.00, p < .049, for moderately
serious problems (Table 3). Subjects were
more likely to endorse breaching confiden-
tiality in the moderately serious client
problems condition. For the second ques-
tion (concerning to whom the information
should be divulged), simple frequency
counts were conducted because subjects had
been inadvertently allowed to check more
than one person. The results suggested that
the most popular choices were another col-
league and parents followed by a friend, a
supervisor and head of the dorm, respec-
tively. Also, for highly serious and moder-
ately serious problems parents were chosen
equally. However, in choosing colleague and
supervisor, subjects discriminated between
highly serious and moderately serious
problems such that only for high serious
problems would they more frequently en-
dorse disclosure to a colleague or supervisor.
Finally, police was not chosen as a possible
source by any subject.
250 THOMAS V. MERLUZZI AND CHERYL S. BRISCHETTO
Discussion
The Confidentiality X Problem Serious-
ness interaction on trustworthiness indicated
that counselors who breached confidentiality
in cases involving highly serious problems
were perceived as less trustworthy. Ap-
parently, subjects believed that confidenti-
ality was important with problems of a very
serious nature and less critical with moder-
ately serious problems. Perhaps, in the
highly serious situations with more drastic
consequences, subjects' ratings reflected how
the breach in confidentiality might erode the
counselor's trustworthiness. With moder-
ately serious problems, on the other hand,
subjects did not foresee any serious conse-
quence if the information was released. In
that condition it made little difference
whether the counselor divulged information
or maintained confidentiality: the coun-
selor's trustworthiness was not compro-
mised. Although no norms are available for
the CRF scales, the mean trustworthiness
score obtained by counselors in the high-
problem-seriousness-nonconfidential con-
dition was very low compared to scores ob-
tained in other studies the authors have
conducted. Additionally, subjects were
more likely to refer friends, to feel the client
was better understood, to suggest a more
favorable outcome and see the counselor as
more attractive in instances in which coun-
selors maintained confidentiality. Finally,
the comparable trustworthiness scores in the
Confidential and Control conditions suggest
that in the absence of a confidentiality ma-
nipulation subjects assumed that confiden-
tiality would be maintained.
In addition to the major findings reported
above, information was gathered on ques-
tions that might suggest how subjects felt
about the problem of confidentiality. With
highly serious problems subjects registered
an equal frequency of yes and no responses
concerning whether the information should
be divulged. However, inspection of Table
3 reveals that in the control condition more
subjects favored maintaining confidentiality.
With moderately serious problems the
subjects were more likely to favor divulging
the information. That effect was most
prominent in the control conditions in which
no cues concerning the counselor's intent
were given. These findings reinforce the
results obtained on trustworthiness ratings:
With serious problems confidentiality is
preferred.
On the question concerning who would be
the most appropriate referral source, the
most popular choices were another colleague
and parents, followed by a friend, supervisor,
head of the dorm. Police was not chosen by
any subjects as a potential referral source.
For more personal sources like parents,
subjects endorsed disclosure for highly se-
rious and moderately serious problems with
equal frequency. However, for more im-
personal sources like a colleague or super-
visor, they more frequently endorsed dis-
closure only in cases of highly serious prob-
lems.
The results of this study are preliminary
and, by the very nature of the problem, are
based on analogue methodology. However
preliminary the findings, the results suggest
that even in circumstances in which coun-
selors are reasonably emphatic and caring
as well as deliberate in their decision to
breach confidentiality, trustworthiness is
compromised. In contrast to the extreme be-
haviors used to enact untrustworthy be-
havior in previous studies, the present study
suggests that confidentiality alone may be a
key ingredient in perceived trustworthiness.
Moreover, the decrement in trustworthiness
may occur primarily in situations in which
the clients' concerns are of highly serious
nature. The results should not lead to the
conclusion that we should abandon breach-
ing confidentiality under any circumstances.
Rather it suggests that the decision to do so
is associated with specific consequences that
may affect the counselor's ability to be in-
fluential with the client.
It is interesting to note that degree of ex-
perience did not affect perceptions of
trustworthinessnor was there any inter-
action of experience with any other inde-
pendent variables. One might have antici-
pated that highly experienced counselors
may not have been seen as less trustworthy
in situations in which confidentiality was
breached. Possible explanations of the ob-
tained findings are that (a) the experience-
level manipulations were weak, (b) the
quality of the counselors' responses in the
dialogue may have dispelled the notion that
CONFIDENTIALITY AND TRUSTWORTHINESS 251
the nonexperts were also incompetent, or (c)
the confidentiality manipulations "masked"
or neutralized the experience-level differ-
ences.
As noted above, a limiting factor in this
study is the fact that it was conducted via
audiotaped, contrived counselor-client in-
teractions. Although one would not conduct
this research with actual clients for obvious
ethical reasons, it may be conceivable to
approximate more closely the counseling
situation. It is our opinion that face-to-face
interaction and the counseling relationship
might modify, somewhat, the impact of
breaching confidentiality. Perhaps the
quality of the relationship could be manip-
ulated in an analogue setting by varying the
level of empathy, respect, and genuineness
displayed by the counselor. The reality of
the situation might be enhanced by having
the subjects role-play a client after an elab-
orate role induction. The major hypothesis
might be that the quality of the relationship
may be determinant of the subject's (client's)
perception of the counselor who breaches
confidentiality.
N
Thus, loss of trustworthi-
ness may be attenuated in the context of a
high quality therapeutic relationship.
Conclusion
A recent court case, Tarasoff v. Regents of
the University of California (1974)
prompted us to look more closely at the area
of confidentiality and its relationship to
perceived trustworthiness. That case has
been the impetus for many recent publica-
tions in law, psychology, and psychiatry that
examine and debate the importance of con-
fidentiality in counseling (Stone, 1976).
There are those who argue that counselor-
client privilege must be preserved at all costs
lest the counseling relationship be destroyed
and the counseling process rendered useless.
Others are convinced that confidentiality
should be violated when certain conditions
prevail. Although it is beyond the scope of
this study to resolve the issues involved in
the Tarasoff decision, it does suggest that
confidentiality may directly affect perceived
trustworthiness. Perhaps as research de-
velops in this area we may begin to accu-
mulate evidence that may be valuable to
those involved in the legal decision making
process.
References
American Psychological Association. Ethical princi-
ples of psychologists. American Psychologist, 1981,
36,633-638.
Barak, A., & LaCrosse, M, B. Multidimensional per-
ception of counselor behavior. Journal of Counsel-
ing Psychology, 1975,22, 471-476.
Corrigan, J. D., Dell, D. M., Lewis, K. N., & Schmidt, L.
D. Counseling as a social influence process: A re-
view. Journal of Counseling Psychology, 1980,27,
395-441.
Heppner, P. P., & Dixon, D. N. A review of the inter-
personal influences process in counseling. Personnel
and Guidance Journal, 1981,542-550,
Kirk* R. Experimental design: Procedures for the
behavioral sciences. Belmont, Calif,: Brooks/Cole,
1968,
LaCrosse, M. B., & Barak, A. Differential perception
of counselor behavior. Journal of Counseling Psy-
chology, 1976,23,170-172.
LaFromboise, T. D., & Dixon, D. N. American Indian
perception of trustworthiness in a counseling inter-
view. Journal of Counseling Psychology, 1981,28,
135-139.
Rothmeier, K., & Dixon, D. N. Trustworthiness and
influence in a counseling interview. Journal.of
Counseling Psychology, 1980,27,315-319.
Stone, A. The Tarasoff decisions: Suing psycho-
therapists to safeguard society. Harvard Law Re-
view, 1976,90, 358-378.
Strong, S. R. Counseling: An interpersonal influence
process. Journal of Counseling Psychology, 1968,
15, 215-224.
Tarasoff v. the Regents of the University of California
et al, Sup. 118 (California Rep. 1974,129-145).
Received April 29,1982
Revision received November 5,1982

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