A Missouri Court of Appeals has upheld most of a jury’s decision against a licensed therapist who became sexually involved with a woman during her counseling sessions, but it has removed $1 million in punitive damages from the judgment. The case, Anita Karase v. Craig Politte, was decided on November 10, 2026, and centres on allegations that Craig Politte exploited the therapeutic relationship with Anita Karase, a woman he had initially counselled alongside her husband, as mentioned on Justia U.S Law’s website.The appeals court affirmed the jury’s findings on medical negligence, battery, and a violation of the Missouri Merchandising Practices Act. It reversed only the negligence per se claim, which had carried the $1 million punitive award, because it found that Missouri’s counselor ethics regulations do not create a separate private cause of action for that type of claim.
How the relationship began
According to the court record, Politte began counselling Karase’s husband in 2018 through his private practice, Life Counseling Centers. He later provided couples therapy to Karase and her husband, then began seeing Karase individually.The court found that Politte did not discuss the potential conflict created by simultaneously providing couples and individual counseling to the same couple. Karase also did not sign an informed consent form before beginning therapy. After several individual sessions, Karase told Politte she was attracted to him. Physical contact between them intensified during sessions and eventually led to sexual acts, including intercourse.
What the court found
The jury found in Karase’s favour on all four counts. It awarded her $1,135,120 in compensatory damages and $1 million in punitive damages, for a total judgment of more than $2.1 million, as per the record. The jury assigned 99 percent fault to Politte and 1 percent fault to Karase on the medical negligence claim. On the negligence per se claim, it assigned 100 percent fault to Politte.Karase’s expert witness, licensed psychologist Dr. Catherine Hassler, testified that Politte breached the standard of care by treating both Karase and her husband and by failing to refer Karase to another counselor when she disclosed feelings for him. The court record notes that Politte admitted his conduct fell below the standard of care and that the sexual acts were intentional and harmful.
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Why the punitive damages were removed
The appeals court’s decision to strike the $1 million punitive award came down to a legal distinction. The jury had found Politte liable for negligence per se, a claim based on the argument that he violated specific professional regulations.But the appeals court held that Missouri’s counselor ethics regulations do not create a private cause of action that can support a negligence per se claim. In other words, while the regulations may justify professional discipline, they do not automatically give a client the right to sue for damages under that particular legal theory.Because the punitive damages were tied to that count, the court reversed that portion of the judgment and remanded the case for further proceedings. The rest of the jury’s verdict, including the compensatory damages, was affirmed.
The human cost
The case is not only about legal technicalities. It involves a woman who sought therapy during a difficult period in her life and later said she felt exploited by the person she trusted to help her.Karase told the court that she sought therapy with three other providers after the relationship ended, paying between $125 and $250 per session. She said she will need long-term mental health care because of the harm she experienced.The court also noted that Karase and her husband were in divorce proceedings by the time the relationship came to light. Karase initially resisted identifying Politte to her husband, hoping to protect him, before eventually disclosing what had happened.
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What happens next
The appeals court’s ruling narrows the financial outcome but does not erase the jury’s finding that Politte was responsible for the harm Karase suffered. The compensatory damages remain in place, and the case will return to the lower court for further proceedings on the reversed count.The decision also clarifies an important legal boundary in Missouri. Professional ethics rules can lead to license discipline, but they do not necessarily create an independent path for a negligence per se lawsuit unless the legislature has clearly intended that result.For patients, the case is a reminder that the therapeutic relationship carries a duty of care. For counselors, it underscores that crossing professional boundaries can have consequences that extend beyond licensing boards and into the civil courts.