Law & Ethics of Clinical Documentation for a Post Roe World

1 CE Credit Hour. Legal-Ethical. Self-Study Seminar w/ Videos

Presented By: Eric Ström, JD PhD LMHC & Liath Dalton

This 1 hour CE workshop will address the practical applications of the US Supreme Court’s recent ruling in Dobbs v. Jackson Women’s Health Organization.  Particular focus will be on the impacts this decision has on client confidentiality and documentation of clinical services.

Course Description

Educational Objectives

After this workshop, participants will be able to:

  1. Describe the impact of the US Supreme Court’s Roe v. Wade decision
  2. Describe the impact of the US Supreme Court’s Dobbs v. Jackson decision
  3. Outline some significant impacts of the Dobbs v. Jackson decision
  4. Articulate strategies to protect client interest given the Dobbs v. Jackson decision


  1. Summary of Roe v. Wade
  2. Summary of Dobbs v. Jackson
  3. Impact of Dobbs v. Jackson
  4. State variation
  5. State jurisdiction
  6. Clinical Documentation


California Health and Human Services Code §123467.5

Dobbs v. Jackson Women’s Health Organization, No. 19-1392, 597 U.S. ___ (2022)

International Shoe Co. v. Washington, 326 U.S. 310 (1945)

Jane Roe, et al., v. Henry Wade, 410 U.S. 113 (1973)

Planned Parenthood v. Casey, 505 U.S. 833 (1992)

Revised Code of Washington 9.02.110

Revised Code of Washington 18.130.180

Roe v. Wade, 314 F. Supp. 1217 (N.D. Tex. 1970)

1 CE Credit Hour.

Presented/Developed By

Eric Ström JD PhD LMHC, is an attorney and Licensed Mental Health Counselor in Seattle, Washington. As an attorney, Eric provides legal counsel, consultation, and guidance to mental health professionals. Eric’s counseling practice is focused on providing counseling services to combat veterans as well as providing supervision and consultation to other clinicians. Eric currently serves on the American Mental Health Counselors Association Ethics Committee, and is the ethics advisor for the Washington Mental Health Counselors Association. Eric has taught a range of courses in counseling and professional ethics at a variety of graduate and undergraduate programs.

Eric earned a PhD in Counselor Education and Supervision at Oregon State University, a Master of Arts Degree in Counseling Psychology from the Northwest School of Professional Psychology at Argosy University Seattle, graduated cum laude from Wayne State University School of Law in Detroit Michigan, attended the Hague Academy of International Law in the Hague Netherlands, and received a Bachelor of Arts degree in Linguistics from the University of Michigan.


Liath Dalton is PCT’s director and a co-owner. Liath is especially passionate about helping therapists be resourced and supported in navigating the security compliance process and identifying the solutions and processes that meet the particular needs of their practices. Liath’s consultation area of expertise is focused on selecting the right combination of services and tech that not only meet the legal-ethical needs of mental health practices, but also the functionality, efficiency, and cost-effectiveness needs as well.

Program Notices

Accuracy, Utility, and Risks Statement:

This program discusses strategies for complying with HIPAA and some other US Federal rules. It may not include information on all applicable state laws. Misapplication of the materials, or errors in the materials, could result in non-compliance with applicable laws or ethics codes.

Conflicts of Interest: None given.

Commercial Support: None.

This course is subject to our cancellation/refund policy and complaint policy.

1 CE Credit Hour.

1 CE Credit Hour. Legal-Ethical. Self-Study Seminar w/ Videos


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