Olson
Olson v. Morris
Opinion
Lead Opinion
Silverman, J.
Dr. Kenneth Olson, a licensed psychologist, performed an exorcism on a child believed to have been the victim of Satanic ritual abuse. Although Olson is also an ordained minister, the boy had been referred to Olson solely for psychological evaluation and treatment. On complaint made by the child welfare caseworkers who had referred the youngster to Olson, the Arizona Board of Psychologist Examiners conducted a hearing, concluded that Olson had engaged in unprofessional conduct, and revoked his license. Instead of appealing the Board’s action to the Arizona Superior Court as state law allows, Dr. Olson filed a federal lawsuit against the Board and its members asserting constitutional defenses to the license revocation — defenses that were raised, or could have been raised, at the Board hearing. We hold that the doctrine of res judicata prevents Dr. Olson from relitigating in federal court legal and factual issues that *1085 were, or could have been, litigated before the Board. We affirm the district court.
1. Background
Kenneth J. Olson, Ed.D., a clinical psychologist and ordained Lutheran minister, was contacted by the foster father of an 8-year-old boy. The foster father…