Dual Relationships When Clergy Counsel Congregants

By Jessica A. Justice, MSW, and Diana Garland, LCSW, PhD

Every human interaction involves interpretations of roles and interpersonal boundaries. These roles and boundaries dictate appropriate versus inappropriate behavior between a person and family, friends, co-workers, and professionals, ultimately helping society to create a sense of structure and expectations for social interactions. However, when an individual functions in multiple roles with another person, the interpersonal boundaries can become ambiguous. When a professional has more than one role with another person for example, "as both a friend and teacher, or as a doctor and next-door neighbor" the professional is in a "dual relationship." Gabriel (2005) suggests that a dual relationship exists when "a one-to-one contracted therapy relationship occurs between an individual in a therapeutic role of 'client' and another individual in the role of 'therapist' overlaps into a non-therapy context or role" (p 128). Another definition of a dual relationship is that it consists of "two or more distinct kinds of relationships with the same person" (Endacott et al, 2006, p 988; Judd et al, 2002). Even though some professions permit and even encourage professionals to interact with their clients in various kinds of relationships (Bleiberg & Skufka, 2005), dual relationships can become especially problematic when the professional role is that of a therapist. The therapeutic environment requires a high level of trust, vulnerability, and confidentiality. It is essential to the client-counselor relationship for the counselor to avoid interacting with the client in other roles where that vulnerability and confidentiality may be breached. For example, if a counselor is also married to a client's best friend, the counselor must remember what she knows about the client from the informal friendship, and what she knows from the counseling relationship, and not get the two confused. Also, the client is left wondering what the counselor may tell his best friend that she learned in the counseling sessions. Such a dual relationship makes it difficult for the client to feel safe in either relationship.

Pastors who offer counseling to their congregants automatically create a similar complex dual relationship. Because clergy provide for the spiritual needs of their congregants both in and outside the walls of a church (e.g., church sanctuary, public spaces, private homes, etc.) religious leadership often involves dual relationships between pastors and congregants. In fact, because pastors are often considered "friend, teacher, spiritual advisor, shepherd, and sometimes even coworker" to their congregants (Parent, 2005, p. 8), they must be able to quickly adapt to different social expectations, circumstances, and levels of intimacy. This flexibility is necessary for a pastor to provide for the overall needs of his/her congregation, but it nevertheless endangers the counseling relationship, which needs to be governed by well-defined boundaries and predictability. Boundaries help to maintain the client's privacy by establishing rules for confidentiality, but they also serve a variety of other functions. As Welfel (2002) described, "Boundaries provide structure for the [counseling] process, safety for the client, and the required emotional distance for effective therapeutic work" (p. 155).

Dual relationships can create numerous opportunities to violate boundaries and confidentiality with a client. Even though the pastor may not intend to break confidentiality in a given situation, casual conversations with others outside the therapeutic relationship provide a perfect opportunity for an innocent slip-of-the-tongue. Even when such a slip does not occur, the congregant may be anxious that it might happen. When a pastor inadvertently does disclose information about a congregant, harmful or embarrassing rumors can circulate, likely dissolving the trust needed to sustain a therapeutic relationship.

The role of pastoral leadership also is quite different from that of counselor. A religious leader may exhort a congregation to believe or act in ways particular to that church's or denomination's beliefs. Counselors, on the other hand, are diligent to protect the client's right to self determination, even if the client's choices are contrary to the beliefs or actions to which the religious community adheres. In such a situation, the religious leader acting as a counselor would be in an untenable position.

Generally, we use boundaries in social interactions to help us cope with "power and vulnerability in relationships" (Parent, 2005, 6). However, clergy sometimes overlook the power of their position (Robison, 2004) and are not always aware of their influence over their congregants, who often regard them as spiritual authorities and "may grant [clergy] with extraordinary trust, power and authority" (Parent, 2005, 9). This discrepancy in perception may result in the pastor minimizing or ignoring boundaries, creating an environment in which predisposed clergy can misuse the power they have to exploit vulnerable congregants. Clergy should consider carefully the implications of that power both as a pastor and spiritual authority and as a counselor.

Religious leaders should protect the well-being of their congregants by avoiding the confusion of roles and boundaries created by functioning as both pastor and therapist to a member of their congregation. In an article by Craig (1991), he asserts that regardless of rationalization or intention of the clergy, "dual relationships cloud the counselor's clinical judgment and lead to client abuse" (p. 49), ranging from exercising control over decisions the client makes to actual illegal behavior. Dual relationships and misuse of power can only be avoided by "understanding vulnerability, subscribing to and communicating a clear code of professional ethics, becoming aware of personal limitations, and building networks of accountability" (p. 49).

Licensed social workers and professional counselors have codes of ethics that proscribe dual relationships and guide the professionals through various ethical issues and dilemmas. Violation of these codes carries a heavy penalty and even loss of license. No formal ethical guidelines are currently required for pastors, however. We, therefore, make the following recommendations:

1. Religious groups should establish ethical codes of conduct that give clear guidance to the roles that religious leaders should and should not assume with those they lead (a sample code follows this article).

2. Religious leaders should limit their professional roles to that of pastor, even if they have clinical professional credentials, with those they serve as pastor, teacher, or religious colleague.

3. Congregations should develop clear accountability structures for their leaders that provide the leaders guidance and consultation in the navigation of their multiple roles and responsibilities on a regular, scheduled basis.

4. Religious leaders should treat congregants with dignity, respect, and compassion and lead their congregations with humility and integrity, remaining aware of their influence over congregants and of their personal struggles.

5. Religious leaders should identify available resources in the community to help provide referrals for the various physical and mental health needs of those they lead.


Bleiberg, James R. & Skufka, Laura. (2005). Clergy dual relationships, boundaries, and attachment. Pastoral Psychology, 54(1), 3-22. Craig, James D. (1991). Preventing dual relationships in pastoral counseling. Counseling & Values, 36(1), p 49-54.

Gabrielle, Lynne. (2005). Speaking the unspeakable: The ethics of dual relationships in counseling and psychotherapy. Hove, Routledge. " Morrison, Bradley T. (2005). Stewardship models of pastoral care, counseling and supervision: The Commonians meet Ricoeur at worship. Pastoral Psychology, 53(5), p 435-446.

Parent, Miriam S. (2005). Boundaries and roles in ministry counseling. American Journal of Pastoral Counseling, 8(2), p 1-25.

Robison, Linda H. (2004). The abuse of power: A view of sexual misconduct in a systemic approach to pastoral care. Pastoral Psychology, 52(5), p 395-404.

Streets, Frederick, Grumbacher, Peter, Thomas, Taylor E., & Bleich, Moshe. (2008). The value of social work education for the religious professional. Journal of Jewish Communal Service, 83(2/3), 177-185.

Welfel, Elizabeth R. (2002). Ethics in counseling and psychotherapy: standards, research and emerging issues. (2nd ed.) Pacific Grove: Brooks/Cole.