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O R I G I N A L P A P E R

When Social Workers Are Stalked: Risks, Strategies, and Legal Protections

Cheryl Regehr • Graham D. Glancy

Published online: 1 October 2010

� Springer Science+Business Media, LLC 2010

Abstract By virtue of their work, social workers are at

risk of becoming victims of stalking. This is because social

workers assist individuals who suffer from major mental

health problems that may cause them to develop delusional

beliefs about their therapists, and because social workers

may need to exercise authority against individuals with

personality disturbances that present a risk to others. Sur-

veys suggest that 16% of social workers have been stalked

at one point in their career by a client. Stalking of social

workers by clients has far-reaching personal and profes-

sional implications, potentially affecting all aspects of an

individual’s life. This paper reviews the nature and inci-

dence of stalking of social workers, the legal remedies

available to social workers who are victims of stalking, and

strategies for protection.

Keywords Social workers � Stalking � Violence � Threats � Client

From 1996–2002, Shauna Bailey, a social worker in Lon-

don England, was stalked by her client Richard Jan.

Ms. Bailey was a member of a mental health team that

assessed Mr. Jan under the Mental Health Act after they

were contacted by his mother regarding her concerns about

his mental health and his threats to harm her. He was

arrested in the community under mental health legislation

but was then later released from hospital as he did not meet

the criteria for involuntary admission. This marked the

onset of Jan’s harassment of Ms. Bailey and others. Ms.

Bailey sustained injuries requiring hospitalization on two

occasions after being attacked on the front doorstep of her

home late at night by Jan. He bombarded her with phone

calls. He followed her car, smashed it up, and set it on fire.

The ordeal ended when Ms. Bailey moved from her home,

quit her job and changed her name. In his 7 years of

inflicting terror on Ms. Bailey, Jan also had numerous other

victims including a west London City Councillor whose

home he firebombed. Jan, who was dubbed by Detective

Chief Inspector David Poole as ‘‘Britain’s worst stalker’’,

was convicted in 2004 on two counts of arson and causing

a public nuisance (BBC 2004; Mintowt-czyz and Edwards

2004).

While dramatic incidents such as that of Shauna Bailey

may be rare, they are not isolated. A Canadian random

survey of 171 social workers found that 16.3% reported

being stalked at some point in their careers (MacDonald

and Sirotich 2005). Other surveys while not specifically

addressing stalking behavior, report high rates of threats

and actual harm to social workers by clients (MacDonald

and Sirotich 2001; Newhill 1996; Rey 1996; Regehr et al.

2004). For instance, MacDonald and Sirotich (2001, 2005)

indicate that 87.8% of social workers in their study

reported verbal harassment, 63.5% reported threats of

physical harm, and 28.6% report being assaulted by a

client. A random sample of 1,129 social workers in two

states revealed that 83% had been threatened with harm,

and 40% had experienced an attempted or actual assault.

C. Regehr (&) Faculty of Social Work and Faculty of Law,

University of Toronto, 27 King’s College Circle,

Toronto M5S 1A1, ON, Canada

e-mail: [email protected]

G. D. Glancy

Faculty of Medicine, University of Toronto,

Toronto, ON, Canada

G. D. Glancy

Faculty of Medicine, McMaster University,

Hamilton, ON, Canada

123

Clin Soc Work J (2011) 39:232–242

DOI 10.1007/s10615-010-0303-4

Rey (1996), in a study of 175 social workers, found

reported rates of threats and assaults at 59.6 and 23%,

respectively. In this sample 24.2% had objects thrown at

them and 17.5% reported threats with a weapon. Practice

settings where social workers are most likely to report

violence include child protective services, mental health

services, substance abuse services, and correctional ser-

vices (Jayaratne et al. 2004; Newhill 1996; Schultz 1987).

While threats and violence cannot be directly equated with

stalking, they often become part of the overall picture of

stalking and point to general concerns about safety for

social workers.

Stalking of social workers and other mental health

professionals by clients is a serious issue that has far-

reaching personal and professional implications. This paper

reviews the nature and incidence of stalking of social

workers and other mental health professionals, the legal

remedies available to professionals who are victims of

stalking, and strategies for protection.

The Incidence of Stalking

A large number of studies have attempted to determine the

nature and incidence of stalking in the general population.

The National Crime Victimization Survey in the United

States (U. S. Department and of Justice 1997) found a life-

time prevalence of stalking for women to be 8.1 and 2.2%

for men. By extrapolation, this translates to 2.04 million

women and 820,000 men in the United States who, at some

time in the lives, have been victims of stalking behavior

(Douglas and Dutton 2001). Extrapolating from the data

gathered by a Statistics Canada study surveying police

forces in Canada on the incidence of reported stalking

during 1994 and 1995 (Kong 1996), Douglas and Dutton

(2001) estimate stalking to have been reported in about 1%

of the adult population of Canadians during that 2 year

period. In a review of studies on stalking by Spitzberg and

Cupach (2007), between 60 and 80% of the victims were

female. A U.S. national survey on violence against women,

found that physical violence was reported in 32% of

stalking cases and sexual violence was reported in 12% of

stalking cases (Tjaden and Thoennes 1998).

Stalking emanating from domestic violence is the most

common form of stalking; encompassing an estimated

75–80% of all cases in some studies (Roberts and Dzieg-

ielweski 2006). Burgess and colleagues (1997) studied 120

people charged with domestic violence, who were attend-

ing a treatment program, of whom 30% admitted to

stalking their partners. Those that did stalk a former partner

had more serious histories of domestic violence. Thus,

social workers are most likely to be involved in stalking

situations where a client is being stalked by a former

intimate partner and the social worker acts in a helping

role. A body of literature addresses appropriate advice and

supports that social workers can provide to clients in this

situation. While it is critical for social workers to have

knowledge to help others, this paper focuses on social

workers as victims.

Aside from victims of intimate partner violence, mental

health professionals are one of the highest risk groups for

being stalked. Several randomized surveys have revealed

that between 20 and 30% of psychiatrists and psychologists

report being stalked (Hudson-Allez 2002; McIvor and Petch

2006; McIvor et al. 2008; Purcell et al. 2005). In a random

sample survey of Australian psychologists, 19.5% of the 830

respondents had been stalked, defined as 10 or more intru-

sions persisting for two or more weeks (Purcell et al. 2005).

Of those who reported stalking, 38% received explicit

threats of harm or death and 9% per cent reported being

physically assaulted. An Italian survey found that 11% of

361 mental health workers (including psychiatrists, psy-

chologists, mental health nurses and social workers) repor-

ted being stalked using the criteria of 10 or more unwanted

contacts for a period of more than 4 weeks (Galeazzi et al.

2005). Fifty percent of a convenience sample of 112 mental

health nurses reported at least one stalking experience in

their careers. However, the design of this study does not

allow for generalization of this rate to all mental health

nurses (Ashmore et al. 2006). As noted earlier, a survey of

171 social workers found that 16.3% reported being stalked

at some point in their careers (MacDonald and Sirotich

2005). While methodological issues, including self-selec-

tion bias of some of the survey studies, may account for

variable rates of stalking reported, clearly this is an issue of

significant concern for all mental health practitioners.

Typologies of Stalking

Several authors have attempted to develop typologies of

stalking based on a number of dimensions including the

psychological characteristics of the stalker, and the rela-

tionship between the stalker and the victim (Dziegielewski

and Roberts 1995; Glancy 2008; Zona et al. 1993). These

typologies cover the wide range of stalking situations

spanning from stalking by strangers, to stalking arising

from intimate partner violence, to stalking of famous

people. In one the most well known typologies, Mullen and

colleagues (1999) identified five types of stalkers: (1) the

rejected stalker, who is motivated by a mixture of revenge

and desire for reconciliation after a relationship ends; (2)

the intimacy seeking stalker who often has erotomaniac

delusions; (3) the incompetent stalker who may be intel-

lectually or socially limited; (4) the resentful-retaliatory

stalker who seeks to frighten and distress the victim; and

Clin Soc Work J (2011) 39:232–242 233

123

(5) the predatory stalker who is preparing for a sexual

attack. Motivation for stalking of mental health profes-

sionals most commonly falls under the categories of either

erotomania or resentful-retaliatory stalkers (Hudson-Allez

2002; McIvor et al. 2008; Newman and Appelbaum 2007;

Purcell et al. 2005).

Resentful-retaliatory stalking may arise as a result of

duties performed by the social worker that had an adverse

effect on the stalker, including a negative court report,

apprehending a child in a protection case, or participation

in arranging involuntary admission to a mental health

facility. A study of 175 child welfare workers revealed that

52% of front line protection staff had been threatened with

assault and 19.1% had been physically assaulted when

investigating or intervening in cases of child abuse (Regehr

et al. 2005). Schultz (1987) in a study of 150 social workers

in one U.S. state, indicated that threats towards mental

health social workers frequently occurred when commit-

ment to a mental health facility was discussed, planned or

attempted with a client. In the above-noted case of Ms.

Bailey, her involvement in attempts to admit Richard Jan to

hospital, following threats made toward his mother, pro-

voked retaliatory stalking. In studies of perceived motiva-

tion for stalking of professionals in other mental health

disciplines, 42% of psychologists Purcell et al. (2005), 21%

of therapists (Hudson-Allez 2002), and 34.1% of psychia-

trists (McIvor et al. 2008) who reported being stalked,

believed that the client was angry either because of nega-

tive outcomes of an assessment, or the termination of

treatment. Stalking behavior of mental health professionals

motivated by resentment or retaliation is most commonly

perpetrated by males who have never been married, misuse

substances, have a diagnosis of personality disorder

or major mental illness, have a history of assault and

self-harm, and have repeated hospitalizations (Galeazzi

et al. 2005; Gentile et al. 2002; McIvor et al. 2008;

Rosenfeld and Harmon 2002; Sandberg et al. 1998, 2002).

Erotomania is best described as delusional loving, that

is, a love relationship that exists only in the mind of one

party and which is not based on reality. This syndrome was

first described in 1942 by De Clerambault in his book Les

Psychoses Passionelles and thus has become known as ‘De

Clerambault’s syndrome’. The client suffering from this

syndrome (most frequently a woman) believes that a per-

son of higher social stature is passionately in love with her,

but that this person is restricted from expressing this love

because of external constraints (Purcell et al. 2001). These

constraints can be imagined to be a spouse or family, or

rules that restrict behavior. For instance, the stalker may

believe that the victim would marry her if rules did not

forbid relationships between social workers and clients,

or between students and professors. The stalker may begin

to harass and threaten family members of the victim.

Subsequently, when the love and hope are not realized, the

love can disintegrate to resentment and anger (De Cler-

ambault 1942).

A study of 200 stalkers revealed that 42% of all inti-

macy seeking or erotomanic stalkers targeted professional

contacts (McEwan et al. 2009). Further, 39% of therapists

(Hudson-Allez 2002), 19% of psychologists Purcell et al.

(2005) and 29.3% of psychiatrists (McIvor et al. 2008)

believed that the motivation for stalking perpetrated against

them fell into the category of erotomania. Erotomanic

stalking is most likely to be perpetrated by clients with

mental health problems, commonly those with delusional

disorders or personality disorders (Harmon et al. 1998), and

clients with insecure attachment and preoccupied styles

(Tonin 2004). While an erotomaniac stalker can be very

difficult to dissuade, when compared to other types

of stalkers, generally he or she is least likely to resort

to threats of violence or actual violent activity (Rosenfeld

2000).

Effects of Stalking on Victims

Victims of stalking feel that they are under siege, whether

they are victims of intimate partner violence, famous

people or professionals. Repeated unwanted phone calls are

received where the stalker hangs up immediately, remains

silent, declares love, shouts obscenities or threatens. Calls

are usually received at inconvenient times such as in the

early morning or at work and answering machines are often

filled with the stalker’s messages. Letters are sent

or written messages dropped off. Gifts arrive with some

frequency. The stalker may come to the victim’s home or

office and refuse to leave. In the current days of electronic

communication, stalking can include harassing or threat-

ening e-mail messages, inappropriate e-greeting cards, and

digitally altered pornographic photos that lead to distress of

the victim (Amar 2006; Galeazzi et al. 2005; Glancy et al.

2007; Tjaden and Thoennes 1998). In a study of people

experiencing various forms of stalking conducted by Pathé

and Mullen (1997), 36% of a sample of 100 victims

reported property damage. Cars were covered with graffiti,

paintwork was scratched, and tires were slashed. Homes

were attacked via broken windows and smashed fences. In

addition, in more than half the cases, the stalker made

threats directly to harm the victim or their family and

friends, or threatened to discredit the victim by spreading

malicious gossip. In one-third of the cases the victim was

assaulted.

In light of these repeated attacks on the privacy, prop-

erty and life of the victim, it is not surprising that stalking

victims experience a wide range of social and psycholog-

ical sequelae. In a study of 145 people in the general

234 Clin Soc Work J (2011) 39:232–242

123

population who were victims of stalking, 83% reported

personality changes as a result of being stalked, 41% said

that they felt paranoid, 52% reported being easily fright-

ened, and 27% indicated that they had become more

aggressive (Hall 1998). Symptoms of depression, anger and

helplessness are also reported, occasionally leading to

suicidal ideation (McEwan et al. 2009). In a study of 100

victims of stalking, Pathé and Mullen (1997) indicated that

85% reported increased anxiety, 75% reported over-

whelming powerlessness, 74% reported chronic sleep dis-

turbances and 24% reported suicidal ideation. Similarly, in

a study of mental health professionals who were stalked,

53% reported fear, 43% reported anger, and 28% reported

helplessness (Galeazzi et al. 2005). The arousal, intrusion

and avoidance symptoms associated with post-traumatic

stress disorder are also common among stalking victims.

For instance, 55% of 100 victims reported physiological

startle responses to a knock on the door or telephone ring

(Pathé and Mullen 1997) and 33.9% of 236 stalking victims

met the criteria for PTSD Purcell et al. (2005).

Hall (1998), in a study of stalking victims in the general

population, reported that 88% of respondents were more

cautious as a result of fears caused by stalking. Victims check

their rear-view mirror and drive home by different routes.

Victims begin to avoid any possibility of contact, they restrict

activities, often becoming housebound and refusing to answer

the telephone, and thereby become more isolated from social

supports. These symptoms are likely to be more pronounced

when the stalking involves a former history of violence, when

the number of stalking behaviors increases, or when the

duration of the stalking is prolonged (Kamphuis and Emm-

elkamp 2001; Kamphuis et al. 2003; Pathé and Mullen 1997).

On a social level, the victim’s occupational and educa-

tional status is affected if they reduce their attendance or

have frequent interruptions at work. Pathé and Mullen

(1997) reported that over half of the victims in their study of

stalking victims in the general population decreased or

ceased work or school attendance. Tjaden and Thoennes

(1998) found that stalking ended for 19% of victims in their

study because the victim relocated. Among psychologists

who were stalked, 71% modified aspects of their person and

professional lives, including increasing security, changing

phone numbers, and relocating their offices and or homes

(Purcell et al. 2005). In the clinical experience of the authors

of this paper in forensic mental health and threat assessment,

friends and family are called upon to accompany the victim

to various places or stay at the victim’s home. Family

become distraught that there seems to be no end in sight and

as a result may alternately express anger towards the justice

system for failing to protect the victim, and anger towards

the victim for bringing this into their lives. Social supports

can diminish with prolonged stalking as friends and family

seek to have their own lives return to normal.

Social workers who are stalked by clients may experi-

ence additional reactions related to their roles as therapists

and mental health professionals. Social workers may be

concerned that they have in some way caused the stalking

behavior due to a perceived or actual failure to maintain

clear boundaries or manage counter-transference in the

therapeutic relationship (Lorberg 2002). Mullen and col-

leagues (2009) describe how the termination of a treatment

relationship may be perceived by clients to be a breaking of

an implicit promise. The resulting humiliation may lead to

stalking (Meloy 2002), for which the social worker may

assume a sense of responsibility. Further, the duty of care

which a social worker holds, is challenged when a coun-

selling relationship must be terminated due to harassment

or stalking perpetrated by a client (Seeman 2008).

According to the National Violence Against Women

Survey, 30% of female stalking victims and 20% of male

victims seek psychological counselling as a result of their

victimization (Tjaden and Thoennes 1998). However, ser-

vices for victims of stalking are primarily directed at those

who are victims of stalking by intimate partners or victims

of sexual assault by predatory stalkers (Spence-Diehl and

Potocky-Tripodi 2001). As a result, social workers who

experience stalking may have few places to turn for

assistance.

Stalking Laws

In 1990, in part as a response to a high profile celebrity

stalking case and in part due to repeated cases of ex-partner

stalking and violence, California passed the first stalking

law in the Western world (California Penal Code 1990).

Over the next decade, all U.S. states, Australia, Canada, the

United Kingdom and several Western European countries

followed suit (Dennison and Thomson 2005). These laws

primarily came about as a result of public concern that

members of the community were virtually powerless to

protect themselves against harassing or intimidating

behavior. Prior laws addressing stalking came from a

variety of standpoints, each limited in their ability to

address the pervasive nature of stalking. For instance, in

most jurisdictions, victims could (and still can) obtain a

protection order, a peace bond or a restraining order aimed

at limiting contact between the perpetrator and the victim

(Regehr and Kanani 2006). These forms of restraint gen-

erally arise from civil law and may or may not result in

criminal charges if the named individual breaches the

conditions of the order. However, these orders are highly

criticized in that the onus is on the victim to notify police

about a breach. In addition, concerns have been raised

about the motivation and ability of police to enforce the

orders (Purcell et al. 2004). Indeed, the National Violence

Clin Soc Work J (2011) 39:232–242 235

123

Against Women Survey revealed that 69% of female vic-

tims and 81% of male stalking victims who had obtained

restraining orders indicated that their stalkers had violated

the order (Tjaden and Thoennes 1998).

Other laws cover harassment, trespass or vandalism,

which not only address very specific aspects of stalking

behavior, but also are frequently misdemeanours and

therefore are not given serious attention (Dennison and

Thomson 2005; Purcell et al. 2004). Further, most of the

previous law pertaining to stalking behavior could not be

enacted until the stalker had inflicted physical assault or

property damage. This was exemplified by the testimony of

Sandra Pollard, the mother of a stalking victim, who tes-

tified before the 1992 U.S. Senate Judiciary Committee

Hearings on Antistalking Legislation. ‘‘Despite threats he

has made against our lives, despite repeated violations of

restraining orders, despite the professional assessment of

him as dangerous, both the District Attorney and our own

attorney have said that nothing can be done until he has

‘‘done something’’. What is the ‘‘something’’ they must

wait for him to do? Kidnap [my daughter]? Rape her? Kill

her?’’ (Purcell et al. 2004, p. 159) Public pressure and

concern led to legislative reform aimed at better addressing

the needs of stalking victims.

In the United States, stalking legislation generally cov-

ers repeatedly following or harassing an individual, where

the behavior of the pursuer contains a credible threat of

harm. The Model Anti-Stalking Code for the States

(National Institute of Justice 1996) defines stalking as

repeatedly maintaining a visual or physical proximity to a

person, or repeatedly conveying verbal or written threats or

threats implied by conduct. Available sanctions vary

widely, however. Some states classify stalking as a mis-

demeanour, while others define it as a felony. Even where

there is a felony offense, sentences vary from a maximum

of 12 months in West Virginia to 7 years for an equivalent

offense in Illinois. Further, some states require prior inci-

dents of stalking or the violation of existing protection

orders, while others do not (Dennison and Thomson 2005).

Stalking (defined as criminal harassment) was intro-

duced into the Criminal Code of Canada in April 1993. The

Code stipulates, ‘‘No person shall, without lawful authority

and knowing that another person is harassed or recklessly

as to whether the other person is harassed, engage in

conduct referred to in subsection (2) that causes that other

person reasonably, in all the circumstances, to fear for their

safety or the safety of anyone known to them’’. Prohibited

conduct outlined in the Code includes: repeatedly follow-

ing from place to place the other person or anyone known

to them; repeatedly communicating with, either directly or

indirectly, the other person or anyone known to them;

besetting or watching the dwelling-house, or place where

the other person, or anyone known to them, resides, works,

carries on business or happens to be; or engaging in

threatening conduct directed at the other person or any

member of their family. Criminal conviction of stalking

behavior carries a penalty of up to 5 years imprisonment.

In summary, legislation that has been enacted since

1990 throughout North America has lead to considerable

improvement in legal options available to manage stalking

behavior. Nevertheless, these laws do not provide perfect

protection and victims of stalking, to a large extent, are still

left to their own devices to ensure their safety.

Management of Stalking Behavior

Stalking behavior by clients causes significant distress in

mental health professionals and can at times lead to risk of

violence. The section below discusses strategies for man-

aging stalking behavior. It should be noted, however, that

research evidence is largely absent regarding the efficacy of

specific approaches and thus most suggestions noted below

are based primarily on the consensus of experts in the field.

Prevention

Perhaps the most important aspect of risk management

related to stalking or threatening behavior is prevention.

Prevention can occur at three levels, preventative education

for social workers, individual prevention strategies, and

organizational policies that enhance safety. Violence

prevention training is a part of many agency practices

(Newhill 1996) and generally covers basic physical safety

measures in the office or institution and during home visits,

and means for de-escalating violent encounters (Rey 1996;

Spencer and Munch 2003). In addition, however, it is

important that training addresses issues of boundaries in

professional practice and draws attention to the types of

interactions between clients and mental health profession-

als that may subsequently develop into a stalking situation.

For instance, situations where the worker must be con-

frontational may inadvertently provoke a retaliatory

stalker, while loosening of agency rules for a particular

client may reinforce misperceptions of an emerging ero-

tomaniac stalker. Part of this training should underline the

fact that despite precautions taken by social workers, they

are still vulnerable to stalking and threatening behavior

because of the nature of their occupation.

On an ongoing basis, social workers should be vigilant

about the ongoing possibility of threats to safety. Personal

information shared with clients, or made publically avail-

able, should be kept to a minimum. If social workers are

using social networking sites (such as Facebook), they

should have security settings that limit access only to

known parties. Those working with forensic or other high

236 Clin Soc Work J (2011) 39:232–242

123

risk populations generally refrain from displaying family

photographs or other items that give cues to aspects of their

personal life. Precautionary measures employed by foren-

sic evaluators in a study by Leavitt and colleagues (2006)

included the use of unlisted home phone numbers, post

office boxes, and home and office security systems. Basic

home and private office security should be evaluated and

consideration should be given to the installation of inex-

pensive security measures. Doors and windows should be

locked and outside lights can be installed to illuminate

alleys and backyards. Cars should be parked in well lit

areas and highly identifying licence plates avoided. Any

unusual occurrences or uncomfortable feelings about situ-

ations should give rise to concern (Dietz 1989).

Organizational policies must acknowledge threats to

safety and provide means for social workers to report their

concerns. A survey conducted by MacDonald and Sirotich

(2001) explored reasons that social workers did not report

threats of client violence to agency management. Sixty-five

percent of respondents indicated that they did not report

because they viewed client threats and violence to be part

of the job, and 45% did not report because they were

concerned about negative consequences for the client.

Other reasons for non-reporting included: concern that it

would appear that the social worker could not cope (31%);

concern that the agency would not be supportive (24%);

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