Received 05/22/12

Revised 04/24/13
Accepted 07/12/13
DOI: 10.1002/j.2161-007X.2014.00045.x

Critical Race Theory as a Decisional

Framework for the Ethical Counseling
of African American Clients
Don P. Trahan Jr. and Matthew E. Lemberger
The authors introduce critical race theory as a decisional framework for ethi-
cal counseling, with a focus on racial disparities when working particularly
with African American clients. The authors provide a fictional case example
that explains how this framework can be implemented when conducting
cross-cultural counseling with African American clients. Implications for
counselors are provided.
Keywords: critical race theory, ethical decision making, African Americans

T
he racialization of people has had a profound influence on the help-
seeking experiences of clients in counseling, particularly racial/ethnic
minority clients (Burkard & Knox, 2004; Kearney, Draper, & Baron, 2005).
Given the increasing diversity of the U.S. population, it is almost certain
that professional counselors will encounter clients whose race is different
than that of the counselor (Remley & Herlihy, 2010). Therefore, counseling
frameworks that highlight the persistence of race and how counselors can
commit to ethical decisions are imperative to professional practice.
Solórzano, Ceja, and Yosso (2000) defined race as “a socially constructed
category, created to differentiate racial groups and show the superiority or
dominance of one race (typically Whites) over others” (p. 61). In this defini-
tion, race is a culturally adopted ideology from which members of a racial-
ized nondominant group are generally relegated as subordinate to members
of the dominant group. This ideology affects cultural conventions such as
counseling, which is exemplified by fewer members of nondominant racial
groups seeking out counseling services (Atkinson, Morten, & Sue, 1998;
Leong, Wagner, & Tata, 1995; Neighbors, Caldwell, Thompson, & Jackson,
1994; Thorn & Sarata, 1998) and the differing treatment efficacy outcomes
across such groups (Snowden, 2001).
Professional counselor ethics refer to how conduct is judged in light of
standards endorsed by peers and that maintain the integrity of the pro-
fession as helpful to clients (Remley & Herlihy, 2010). Although generally
devised to be protective of professionals and clients, ethical standards

Don P. Trahan Jr. and Matthew E. Lemberger, Department of Individual, Family, and Community
Education, University of New Mexico, Albuquerque. Correspondence concerning this article should be
addressed to Don P. Trahan Jr., Department of Individual, Family, and Community Education, Uni-
versity of New Mexico, 1 University of New Mexico, MSC05-3040, Simpson Hall 129, Albuquerque,
NM 87131 (e-mail: dtrahan@unm.edu).

© 2014 by the American Counseling Association. All rights reserved.

112 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 112 3/13/2014 11:55:44 AM

 can be limited in that they are often reactive rather than proactive (Corey,
Corey, & Callanan, 2007) and therefore consequential of the social sys-
tem from which they derived. Because this results in professional ethics
as incomplete moral codes (Knapp & VandeCreek, 2003), especially for
underrepresented and disenfranchised social groups, racialized ideology
might not be sufficiently included in the construction and governing of
professional ethics in counseling.
It can be argued that the ACA Code of Ethics (American Counseling
Association, 2005) includes vestiges from the dominant cultural group,
and therefore these codes might lack the nuance to confront hegemonic
values. Alternatively, one might assume that the universality of these
ethical principles is sufficient enough for most counseling circumstances,
independent of considerations of race. However, this assumption negates
the phenomenological basis of the counseling profession (Hansen, 2005);
even if a code is universally ethical, the absence of race as a salient con-
sideration in the construction and promulgation of the code will not be
experienced as personally meaningful to a professional or client who has
been racialized and subjugated.
Various ethical decision-making models have been created to assist coun-
seling practitioners in translating principles to decisions, and the models
serve as mechanisms to guide practice and evaluate the effectiveness of
decisions (Cottone & Claus, 2000). For professional counselors, there are
numerous ethical decision-making models (e.g., Blocher, 1987; Bond, 1993;
Corey et al., 2007; Forester-Miller & Davis, 1995; J. G. Garcia, Cartwright,
Winston, & Borzuchowska, 2003; Herlihy & Watson, 2006; Kenyon, 1999;
Kitchener, 1984; Welfel, 2006). However, there is sparse attention given to
racial differences that exist within counselor–client relationships in these
models, which limits the potential relevance when applied to work with
non-White, non-Western clients. Feminist scholars have argued that most
ethical decision-making models are from a White male perspective and
therefore might reflect dominant cultural mores (Hill, Glaser, & Harden,
1995; Rave & Larsen, 1995). Alternative models that include multicultural
aspects of counseling (e.g., Frame & Williams, 2005; Herlihy & Watson,
2006) distribute race within the broader construct of culture and, thus, do
not necessarily account for the weightiness of race and its historical impact
on certain groups of potential clients.
Although current ethical principles and models are potentially ineffica-
cious in relation to working with ethnic minority clients, it is important that
counselors who integrate racial ideologies in their practice not abandon
universal ethics, professional standards, or extant ethical decision-making
models. Instead, the challenge is to overlay race into the fiber of these tools
for counselors. For example, according to Kitchener ’s (1984) five moral
principles in ethical decision making (i.e., autonomy, justice, beneficence,
nonmaleficence, and fidelity), the concept of nonmaleficence—of causing
no harm to others—means valuing a client’s life and personal dignity

Counseling and Values ■ April 2014 ■ Volume 59 113

ACACVJ_v59_n1_0414TEXT.indd 113 3/13/2014 11:55:44 AM

 with an acknowledgment that racial and ethnic minorities might harbor
feelings of harm as a consequence of racism.
As stated, the inclusion of race in ethical decision-making models does
not necessarily alter the outcomes of the ethical principles or even counsel-
ing decisions related to ethics; instead, the inclusion of race is necessary
to align the decision-making process of counselors with the epistemic
processes of minority clients. For African Americans, in particular, because
race can be an overriding epistemic experience (Gump, 2010), decision-
making models that serve African Americans should be constructed and
applied with the same urgency and consistency. To illustrate the pertinence
of infusing racialized ideology to counseling, we first explicate the rela-
tionship between counseling ethics and racial ideology. Next, to provide
professional counselors with an example of a strategy for working ethically
within a racialized social system, we apply critical race theory (CRT) to
ethical decision making in counseling. Finally, we provide a fictional case
example related to this strategy to illustrate ethical practice.

Professional Counseling Ethics and Race

President Bill Clinton’s Race Advisory Board concluded the following: (a)
Racism is one of the most divisive forces in society, (b) racial legacies of
the past continue to haunt current policies and practices that create unfair
disparities between minority and majority groups, (c) racial inequities
are so deeply ingrained in American society that they are nearly invis-
ible, and (d) most White Americans are unaware of the advantages they
enjoy in society and of how their attitudes and actions unintentionally
discriminate against persons of color (Advisory Board to the President’s
Initiative on Race, 1998). Very rarely are counselors deliberately preju-
diced toward clients (Utsey, Ponterotto, & Porter, 2008). However, even
counselors who are advocates for multiculturalism and social justice are
not exempt from racial biases that are deeply embedded in the Western
collective psyche. In fact, the very nature of counseling is a White hege-
mony, derived from middle- and upper-class White societal norms (Lott,
2002; Smith, 2005). We posit that professional actions must exceed the
minimally sufficient qualities of professional care and extend into advo-
cacy behaviors aimed at individuals and groups in ways that contribute
to a just society (Hays, 2008).
Briggs, Briggs, Miller, and Paulson (2011) asserted that many African
Americans do not trust current mental health practices, which might ac-
count for the lower likelihood of African Americans seeking professional
counseling services. For many African Americans, mental health care typi-
cally occurs within family systems (Thompson, Bazile, & Akbar, 2004) and
other sources of support (e.g., friends, religious leaders), and the lack of
training and limited scope of practice in these areas might not account for
the complex and incalculable mental health needs of African Americans

114 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 114 3/13/2014 11:55:44 AM

 (especially given the pervasiveness of social inequity). Research shows that
African Americans perceive that they are denied equal access and treatment
to mental health services compared with their White counterparts who are
provided with unfettered privileges (Briggs, 2001; Briggs & Leary, 2001;
Briggs & Paulson, 1996; Leary, 2005). Therefore, to understand the racial-
ization of African Americans in the Western society (Bartolome & Macedo,
1997), counselors need to prioritize race in the counseling relationship to
decrease the risk of allowing unmitigated racism to affect ethical decision-
making processes in counseling.
The counselor’s race or ethnicity has been identified as a factor that
contributes to the underutilization of counseling services by African
Americans (Asbury, Walker, Belgrave, Maholmes, & Green, 1994; Okonji,
Ososkie, & Pulos, 1996; Thompson et al., 2004). For example, Asbury et al.
(1994) conducted discriminant analyses and found that racial similarity,
perceptions of the therapist’s competence, and perceptions of the service
process determined clients’ ongoing participation in therapy. Terrell and
Terrell (1984) noted that African Americans who rated high in mistrust
of their therapist were more likely to terminate counseling prematurely.
Furthermore, Nickerson, Helms, and Terrell (1994) noted that African
Americans who rated high in cultural mistrust of Whites were less likely
to seek counseling services. Finally, Thompson et al. (2004) found that
African American male participants were more likely to assert that race
mattered in the therapeutic relationship, based on the historical issues and
experiences of the African American community. Moreover, the participants
noted that discussions of race not initiated by the client were perceived as
indicative of the therapist’s racism and discomfort. Considered together,
these studies reflect the differences between the values of counselors and
many African American clients. To confront the contrast in values, coun-
selors can use conceptual devices such as CRT in a manner that is more
culturally competent, personally relevant, and ethical.

CRT

The most essential construct in CRT is that minority groups are subordinate
to the majority group in terms of power and privilege (Matsuda, Lawrence,
Delgado, & Crenshaw, 1993; Solórzano & Yosso, 2000). CRT is understood to
be any conceptual heuristic that emphasizes racial dynamics, especially the
dynamics pertaining to marginalized racial groups (Crenshaw, Gotanda, Pel-
ler, & Thomas, 1995; Delgado & Stefancic, 2001). According to Schaefer (2006),
because of the sanction of “White privilege” in the United States, racialization
will always be a precursor for cross-cultural relationships among African
Americans and Whites. For example, the United States assumes normative
standards of “Whiteness,” which in turn suppress marginalized racial groups.
CRT illustrates that despite the progress that has been made in the United
States to alleviate racism (Bell, 1987, 1992), it is still ever present and ingrained

Counseling and Values ■ April 2014 ■ Volume 59 115

ACACVJ_v59_n1_0414TEXT.indd 115 3/13/2014 11:55:44 AM

 in contemporary society. CRT attempts to deconstruct race-related paradigms
while simultaneously challenging prior research that deemphasizes the im-
portance of race, which is accomplished by demonstrating how the social
construct of race affects marginalized racial groups (Solórzano, 1997, 1998;
Solórzano et al., 2000). CRT theorists proclaim that race must be considered
as a primary cultural determinant (Parker, 1998; Solórzano et al., 2000).
Currently, CRT theorists note that manifestations of racism are more difficult
to recognize because of the discrete manner in which racism is portrayed
(Crenshaw et al., 1995; Delgado, 1995). CRT asserts that the ubiquity of racism
encompasses all people and experiences. Therefore, although counselors might
be operating in accordance with suggested cultural sensitivity models (e.g.,
multicultural counseling competencies, multicultural ethical decision-making
models), the mere emblematic presence of the counselor–client relationship
embodying racial differences will influence the therapeutic relationship.
Although CRT can be puzzling and even disarming for professional coun-
selors, when presented effectively, it can be an important tool to demonstrate
the intercentricity of race. Moreover, CRT can be used to introduce and train
counselors in ethical decision-making processes and social justice behaviors.
To this end, the following three selected CRT tenets—interest convergence,
ordinariness of racism, and narrative storytelling—can be used as strategies
to engage counselors in honest conversations about racism with African
American clients (Crenshaw et al., 1995; Delgado & Stefancic, 2001; S. B.
García & Guerra, 2004; Yosso, 2005).
Interest convergence (also called material determinism) claims that all forms
of racism advance the interests of Whites (Bell, 1980). According to Bell
(1980), Whites will only support social justice to the point that it benefits
them, even change that seems to benefit racialized minorities (e.g., Brown
v. Board of Education, 1954). This is exemplified by research showing that
only 9% of African Americans feel that they are treated the same as their
White counterparts (Briggs et al., 2011; Paul, 2000). Moreover, the exis-
tence of racism and discrimination has produced a variety of defense and
survival mechanisms within the African American community (Schaefer,
2006; Sue & Sue, 2008).
African American clients are more likely to demonstrate reservation
during the first few counseling sessions when faced head-on with the
perceived oppressor (i.e., White counselor). It is therefore imperative that
counselors consider their clients’ worldview rather than opting to refer them
out because of an inability to establish rapport. White counselors need to
be cognizant of how their racial identity may affect racially marginalized
clients, potentially causing African American clients to be resistant during
the initial stages of the counseling process. McIntosh (1998) argued that
White privilege allows for and even encourages a lack of cultural aware-
ness. Recent research, however, suggests that White counselors who em-
brace broaching (i.e., directly inviting clients to explore issues of diversity)
are more likely to receive high ratings of credibility and develop strong

116 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 116 3/13/2014 11:55:44 AM

 working alliances with clients of color (Zhang & Burkard, 2008). Thus,
instead of counselors avoiding the preconceived racial disparities that the
tenet of interest convergence portrays, they can approach it head on. For
example, White counselors can explore how their own cultural heritage
has influenced various attitudes, values, and biases with clients, which in
turn will help establish trustworthiness.
Ordinariness of racism suggests that racism invariably exists at all times and
in all social structures in Western society (Delgado & Stefancic, 2001), and
actions intended to eliminate racism at best only remedy the most conspicu-
ous and superficial forms of racism. For example, adopting a color-blind
ideology proclaims that racism has changed when in fact this notion per-
petuates blatant forms of discrimination. This tenet can be used as a means
to address the personal and interpersonal aspects of cross-cultural learning
between the counselor and client (Arredondo & Perez, 2006). The client’s
self-identification (e.g., ethnic/racial identity, sexual orientation, religion)
can be one of the most important components to explore during therapy,
and counselors should allow ample time for processing. Exploring this dif-
ference openly has the potential to strengthen the therapeutic relationship.
As previously stated, even counselors who are advocates for multicultural-
ism are not exempt from deeply embedded racial/ethnic biases. Therefore,
counselors can use the tenet of ordinariness of racism to reflect on both their
own and clients’ personal biases. Self-disclosure in this case can be used as
a means to strengthen rapport and reduce the likelihood of clients termi-
nating prematurely. According to Remley and Herlihy (2010), to develop
competence with race-related issues, counselors must understand clients’
racial identity development and be able to recognize their own racial identity
development status.
Narrative storytelling is the form of expression that CRT theorists recom-
mend racial/ethnic minorities use when describing their experiences with
racism (Delgado, 1995; Delgado & Stefancic, 2001; Litowitz, 1997). Narra-
tives are commonly used in the African American community (Paul, 2000).
This tenet will provide counselors with an in-depth understanding of the
client’s worldview as it relates to previous encounters with racial disparities.
Narratives can empower African American clients to articulate how racism
has affected them and assist counselors with selecting helping strategies
that are appropriate based on the client’s worldview. Moreover, narrative
storytelling will help counselors understand a client’s defensive nature and
avoid misinterpreting a client’s culturally learned patterns of communicating
(both verbal and nonverbal).

The Case of Demarcus

Demarcus (fictional client), a 21-year-old African American male university

student from Atlanta, Georgia, is referred to counseling by an advisor in
the African American Student Services at the university. He has been strug-

Counseling and Values ■ April 2014 ■ Volume 59 117

ACACVJ_v59_n1_0414TEXT.indd 117 3/13/2014 11:55:44 AM

 gling with several of his courses and is considering dropping out of college
because he feels that some faculty members deliberately single him out
because he is one of the few African Americans in his classes. Moreover,
he feels that because he is an African American man, the “White man” is
out to get him. Therefore, Demarcus has developed an extreme hatred for
White people. As a result, Demarcus has recently demonstrated “out-of-
control behavior,” including drug use and abuse, putting his fist through
his dorm room wall, and frequent verbal outburst during classes. Demarcus
shares with the student services advisor that he feels that he would get
a better education at a historically Black college or university because he
would be among people who understand him (i.e., other African American
students and faculty).
During his first session, Demarcus was withdrawn and made very little
eye contact with John, a White counselor at the university counseling center.
Each question that John asked Demarcus was answered aggressively with a
closed-ended response. John noted that Demarcus clenched his fists during
the entire session and made racial slurs under his breath. After the same
pattern in the second and third sessions, John is frustrated by his inability
to establish a therapeutic alliance with Demarcus and decides that it might
best to refer him to another counselor.
CRT can be used to increase counselor ethical awareness related to race
and, therefore, improve practice as it applies to the specific needs of De-
marcus as an African American client. The focus of most counselors during
the initial session, regardless of their theoretical orientation, is to build
rapport and gather as much background information as possible relating
to the client’s presenting problem. According to Hays (2008), this process
is twofold: (a) The counselor is attempting to understand the unique needs
of the client and explain how he or she can help the client return to a state
of well-being, and (b) the client is attempting to assess the competence and
trustworthiness of the counselor while at the same time trying to evaluate
if the benefits outweigh the risk factors (e.g., time, financial commitment,
effort, embarrassment) associated with counseling.
In the case of Demarcus, it is suggested that John develop an under-
standing of how Demarcus perceives the world. Narrative storytelling is
essential here, because John needs to develop an in-depth understanding
of Demarcus’s experiences from his lens. More than mere talking points
to engage the counseling foci or to appear culturally appropriate, John
can ask Demarcus how he might have personally encountered racism as it
pertains to the presenting issues or the process of counseling. The inclusion
of race might provide a deeper understanding of context, in addition to
engendering a sense of humanity for Demarcus, because the counselor and
client embrace social forces from the client’s vantage point. Thus, the most
fundamental ethical principle, to promote client beneficence, is supported
because significant issues of influence are brought into the counseling
interchange. In working with Demarcus, John can focus on the concept of

118 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 118 3/13/2014 11:55:44 AM

 nonmaleficence—above all do no harm—which Kitchener (1984) identified
as the most critical of the ethical decision-making principles.
When John notes that Demarcus is withdrawn and lacks interest in counsel-
ing content, John can apply the tenet of interest convergence to see what it is
like for Demarcus to work with a White counselor. Rather than avoiding the
obvious tension that exists, John can confront the issue head on, validating
how Demarcus feels. From Demarcus’s point of view, John is the same as
the faculty with whom he has been having problems, and therefore working
with John only perpetuates the same ideology (i.e., the White man is out to
get me). By inviting Demarcus to disclose why he feels that working with
John will only advance the best interest of his professors, John will increase
the likelihood of establishing rapport with Demarcus, and Demarcus will be
more likely to let down his guard and open up to John about his presenting
problem. This process will enable John to promote and recognize Demarcus’s
autonomy, thereby increasing the likelihood of establishing fidelity in the
therapeutic relationship.
Demarcus displays similar behavioral patterns during the second and
third sessions, causing John to become frustrated and consider that a
different counselor might be better suited to work with Demarcus. The
tenet ordinariness of racism can be used in this situation to help John and
Demarcus tune in to how their cultural backgrounds and belief systems
affect the therapeutic relationship. If John makes an effort to see the
world through Demarcus’s lens, he may develop a better understand-
ing of the source of Demarcus’s frustration (e.g., past encounters with
White men). Counselors who understand that racism invariably exists
at all times avoid making inaccurate generalizations based on their own
bias, values, and stereotypes (Hays, 2008). Demarcus can develop a level
of trust with John that will in turn distinguish the uniqueness of their
relationship from the racialized society yet not make it exempt from the
reach of persistent racism.
It should be noted that nurturing trust in the therapeutic relationship
may take several sessions. John needs to understand that even though he
may not intend to offend or harm Demarcus in any way, the nature of their
relationship is based on a social encounter in American society. Thus, his
presence alone simulates racism, whether intentional or unintentional.
Unless attention is given to this matter, the therapeutic relationship will
remain stagnant. Once this understanding emerges within John and De-
marcus’s relationship, the objective of justice in the therapeutic alliance,
developing a rationale for differential treatment, will be established.
In addition to the manner in which John perceives and engages Demarcus
in the counseling dyad, myriad ethical circumstances remain, as would be
the case in nonracially contrastive counseling relationships. For example,
although the presenting issue for counseling included Demarcus’s belief
that certain faculty members deliberately single him out because of his
race, the use of CRT highlights the importance of the ACA Code of Ethics

Counseling and Values ■ April 2014 ■ Volume 59 119

ACACVJ_v59_n1_0414TEXT.indd 119 3/13/2014 11:55:44 AM

 (ACA, 2005, Standard A.6.b., Confidentiality and Advocacy) in which coun-
selors must obtain client consent before engaging in any advocacy efforts
on behalf of the client. Demarcus might believe that if John were to speak
directly with one of these faculty members, then it would primarily benefit
the faculty member or John as counselor, therefore exemplifying the CRT
concept of interest convergence for the White stakeholders who would
benefit while the African American client would be further entrenched in
uncomfortable tokenism.

Implications for Counselors

Counselors are charged with recognizing the limits of their competencies;
thus, White counselors should seek out continuing educational opportunities
(e.g., workshops, consultation, current literature, cultural-based training)
to improve their understanding and effectiveness when counseling African
American clients (Arredondo et al., 1996). Using this skill set will allow White
counselors to better understand themselves as racial and cultural beings,
which will reduce the likelihood of causing harm to clients whose cultural
identity differs from their own.
Scholars who use CRT tenets in the future should evaluate how this con-
cept can be applied to other racial and ethnic groups (e.g., Hispanic, Native
American, Asian, Pacific Islander) as well as the significance of other cultural
factors (e.g., gender, sexual orientation, religion, national origin) as they
relate to the counseling process. Moreover, it would be beneficial to assess
how the tenets of CRT affect White clients who are being counseled by a
counselor from a cultural minority group (e.g., African American, Hispanic,
Asian) in the United States.
Although CRT can serve as a system from which counseling scholars
and practitioners can evaluate the ethical merit of professional practice,
CRT theorists are generally skeptical of traditional research or practice
modalities imbued in White hegemony (e.g., quantifying African Ameri-
can psychopathologies disproportionately to Whites). For this reason,
CRT should be understood as an appropriate means to evaluate and
research the decision-making processes with African American clients.
For example, using an African American client’s personal narrative is
a suggested process in CRT, but to evaluate the degree to which this is
a suggestible and ethical practice needs to be evaluated in conjunction
with the client.
The inclusion of CRT into counselors’ decision-making processes can
lead to better ethical relationships and outcomes, particularly when White
counselors work with African American and other racial/ethnic minority
clients. Moreover, CRT can be extended to illustrate how racial/ethnic mi-
norities and Whites have each been deeply affected by racialized ideologies
and related social power structures. The inclusion of CRT into counseling
practices is not just relevant for White counselors who work with racial/ethnic

120 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 120 3/13/2014 11:55:44 AM

 minorities but rather all counselors who have been affected by hegemonic
social mores. CRT infers the possibility of liberation and development, values
shared within the counseling profession, especially for individuals who are
encouraged to confront those same baleful social forces.

Conclusion
The primary ethical issue related to multicultural counseling is competence
(Pack-Brown, Thomas, & Seymour, 2008). As a profession, counseling
has been relatively slow in addressing the significance between cultural
sensitivity and ethical behavior (Watson, Herlihy, & Pierce, 2006). It is
imperative that counselors acknowledge that Western society includes
prejudicial attitudes and biases and that counselors are not exempt
(Remley & Herlihy, 2010); thus, it is understandable that counselors may
exhibit unethical behavior (e.g., harming a client) without being aware
that they are doing so. The tenets of CRT that we discussed in this article
provide a framework from which counselors can practice, which in turn
reduces the likelihood of clients being harmed because of race-related
issues during the counseling process.

References
Advisory Board to the President’s Initiative on Race. (1998). One America in the 21st century:
Forging a new future. Washington, DC: U.S. Government Printing Office.
American Counseling Association. (2005). ACA code of ethics. Alexandria, VA: Author.
Arredondo, P., & Perez, P. (2006). Historical perspectives on the multicultural guidelines and
contemporary applications. Professional Psychology: Research and Practice, 37, 1–5.
Arredondo, P., Toporek, M. S., Brown, S., Jones, J., Locke, D. C., Sanchez, J., & Stadler, H. (1996).
Operationalization of the Multicultural Counseling Competencies. Journal of Multicultural
Counseling and Development, 24, 42–78.
Asbury, C. A., Walker, S., Belgrave, F. Z., Maholmes, V., & Green, L. (1994). Psychosocial, cultural,
and accessibility factors associated with participation of African Americans in rehabilitation.
Rehabilitation Psychology, 39, 113–121.
Atkinson, D. R., Morten, G., & Sue, D. W. (1998). Counseling American minorities: A cross-cultural
perspective (5th ed.). Madison, WI: Brown & Benchmark.
Bartolome, L., & Macedo, D. (1997). Dancing with bigotry: The poisoning of racial ethnic identi-
ties. Harvard Educational Review, 67, 222–246.
Bell, D. A. (1980). Brown v. Board of Education and the interest convergence dilemma. Harvard
Law Review, 93, 518–533.
Bell, D. A. (1987). And we are not saved: The elusive quest for racial justice. New York, NY: Basic Books.
Bell, D. A. (1992). Faces at the bottom of the well: The permanence of racism. New York, NY: Basic Books.
Blocher, D. H. (1987). The professional counselor. New York, NY: Macmillan.
Bond, T. (1993). Standards and ethics for counselling in action. London, England: Sage.
Briggs, H. E. (2001). Cultural diversity: A latter-day trojan horse. Psychology and Education: An
International Journal, 38, 3–11.
Briggs, H. E., Briggs, A. C., Miller, K. M., & Paulson, R. I. (2011). Combating persistent cultural
incompetence in mental health care systems serving African Americans. Best Practices in
Mental Health, 7, 1–25.
Briggs, H. E., & Leary, J. (2001). Shields and walls: The structure and process of racism in
American society. Psychology and Education: An International Journal, 38, 2–14.

Counseling and Values ■ April 2014 ■ Volume 59 121

ACACVJ_v59_n1_0414TEXT.indd 121 3/13/2014 11:55:45 AM

 Briggs, H. E., & Paulson, R. (1996). Toward a behavioral analysis of racism. In M. Mattaini & B.
Thyer (Eds.), Finding solutions to social problems: Behavioral strategies for change (pp. 147–177).
Washington, DC: American Psychological Association.
Brown v. Board of Education of Topeka, 347 U.S. 483 (1954).
Burkard, A. W., & Knox, S. (2004). Effect of therapist color-blindness on empathy and attribu-
tions in cross-cultural counseling. Journal of Counseling Psychology, 51, 387–397.
Corey, G., Corey, M. S., & Callanan, P. (2007). Issues and ethics in the helping professions (7th ed.).
Belmont, CA: Thompson Brooks/Cole.
Cottone, R. R., & Claus, R. E. (2000). Ethical decision-making models: A review of the literature.
Journal of Counseling & Development, 78, 275–283.
Crenshaw, K., Gotanda, N., Peller, G., & Thomas, K. (Eds.). (1995). Critical race theory: The key
writings that formed the movement. New York, NY: New Press.
Delgado, R. (Ed.). (1995). Critical race theory: The cutting edge. Philadelphia, PA: Temple Uni-
versity Press.
Delgado, R., & Stefancic, J. (2001). Critical race theory: An introduction. New York: New York
University Press.
Forester-Miller, H., & Davis, T. E. (1995). A practitioner’s guide to ethical decision making. Alexan-
dria, VA: American Counseling Association.
Frame, M. W., & Williams, C. B. (2005). A model of ethical decision making from a multicultural
perspective. Counseling and Values, 49, 165–179.
Garcia, J. G., Cartwright, B., Winston, S. M., & Borzuchowska, B. (2003). A transcultural integra-
tive model for ethical decision making in counseling. Journal of Counseling & Development,
81, 268–277.
García, S. B., & Guerra, P. L. (2004). Deconstructing deficit thinking: Working with educators
to create more equitable learning environments. Education and Urban Society, 36, 150–168.
Gump, J. P. (2010). Reality matters: The shadow of trauma on African American subjectivity.
Psychoanalytic Psychology, 27, 42–54.
Hansen, J. T. (2005). The devaluation of inner subjective experiences by the counseling profes-
sion: A plea to reclaim the essence of the profession. Journal of Counseling & Development,
83, 406–415.
Hays, P. A. (2008). Addressing cultural complexities in practice: Assessment, diagnosis, and therapy
(2nd ed.). Washington, DC: American Psychological Association.
Herlihy, B., & Watson, Z. E. (2006). Social justice and counseling ethics. In C. C. Lee
(Ed.), Counseling for social justice (pp. 189–199). Alexandria, VA: American Counseling
Association.
Hill, M., Glaser, K., & Harden, J. (1995). A feminist model for ethical decision making. In E. J.
Rave & C. C. Larsen (Eds.), Ethical decision making in therapy: Feminist perspectives (pp. 18–37).
New York, NY: Guilford Press.
Kearney, L. K., Draper, M., & Baron, A. (2005). Counseling utilization by ethnic minority college
students. Cultural Diversity and Ethnic Minority Psychology, 11, 272–285.
Kenyon, P. (1999). What would you do? An ethical case workbook for human service professionals.
Pacific Grove, CA: Brooks/Cole.
Kitchener, K. S. (1984). Intuition, critical evaluation and ethical principles: The foundation for
ethical decisions in counseling psychology. Counseling Psychologist, 12, 43–55.
Knapp, S. & VandeCreek, L. (2003). An overview of the major changes in the 2002 APA ethics
code. Professional Psychology: Research and Practice, 34, 219–224.
Leary, J. D. (2005). Post-traumatic slave syndrome: America’s legacy of enduring injury and healing.
Milwaukie, OR: Uptone Press.
Leong, T. L., Wagner, N. S., & Tata, S. P. (1995). Racial and ethnic variations in help-seeking
attitudes. In J. G. Ponterotto, J. M. Casas, L. A. Suzuki, & C. Alexander (Eds.), Handbook of
multicultural counseling (pp. 415–438). Thousand Oaks, CA: Sage.
Litowitz, D. E. (1997). Some critical thoughts on critical race theory. Notre Dame Law Review,
72, 503–529.
Lott, B. (2002). Cognitive and behavioral distancing from the poor. American Psychologist, 57, 100–110.

122 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 122 3/13/2014 11:55:45 AM

 Matsuda, M., Lawrence, C., Delgado, R., & Crenshaw, K. (1993). Words that wound: Critical race
theory, assaultive speech, and the First Amendment. Boulder, CO: Westview Press.
McIntosh, P. (1998). White privilege, color, and crime: A personal account. In C. R. Mann &
M. S. Zatz (Eds.), Images of color, images of crime (pp. 207–216). Los Angeles, CA: Roxbury.
Neighbors, H. W., Caldwell, C. H., Thompson, E., & Jackson, J. S. (1994). Help-seeking behav-
ior and unmet need. In S. Friedman (Ed.), Disorders in African-Americans (pp. 26–39). New
York, NY: Springer.
Nickerson, K., Helms, J., & Terrell, F. (1994). Cultural mistrust, opinions about mental illness,
and Black students’ attitudes toward seeking professional psychological help from White
counselors. Journal of Counseling Psychology, 41, 378–385.
Okonji, J. M., Ososkie, J. N., & Pulos, S. (1996). Preferred style and ethnicity of counselors by
African American males. Journal of Black Psychology, 22, 329–339.
Pack-Brown, S. P., Thomas, T. L., & Seymour, J. M. (2008). Infusing professional ethics into
counselor education programs: A multicultural/social justice perspective. Journal of Coun-
seling & Development, 86, 296–303.
Parker, L. (1998). “Race is . . . race ain’t”: An exploration of the utility of critical race theory in
qualitative research in education. Qualitative Studies in Education, 11, 43–55.
Paul, A. M. (2000, October 6). An American health dilemma. Retrieved from http://www.salon.
com/2000/10/06/race_19/
Rave, E. J., & Larsen, C. C. (1995). Ethical decision making in therapy: Feminist perspectives. New
York, NY: Guilford Press.
Remley, T. P., Jr., & Herlihy B. (2010). Ethical, legal, and professional issues in counseling (3rd ed.).
Upper Saddle River, NJ: Pearson.
Schaefer, R. T. (2006). Racial and ethnic groups (10th ed.). Upper Saddle River, NJ: Pearson/
Prentice Hall.
Snowden, L. R. (2001). Barriers to effective mental health services for African Americans. Mental
Health Services Research, 3, 181–187.
Solórzano, D. G. (1997). Images and words that wound: Critical race theory, racial stereotyping,
and teacher education. Teacher Education Quarterly, 24, 5–19.
Solórzano, D. G. (1998). Critical race theory, racial and gender microaggressions, and the
experiences of Chicana and Chicano scholars. International Journal of Qualitative Studies in
Education, 11, 121–136.
Solórzano, D. G., Ceja, M., & Yosso, T. J. (2000). Critical race theory, racial microaggressions,
and campus racial climate: The experiences of African American college students. Journal
of Negro Education, 69, 60–73.
Solórzano, D. G., & Yosso, T. J. (2000). Toward a critical race theory of Chicana and Chicano
education. In C. Tejeda, C. Martinez, & Z. Leonardo (Eds.), Charting new terrains of Chicana(o)/
Latina(o) education (pp. 35–65). Cresskill, NJ: Hampton.
Smith, L. (2005). Psychotherapy, classism, and the poor: Conspicuous by their absence. American
Psychologist, 60, 687–696.
Sue, D. W., & Sue, D. (2008). Counseling the culturally diverse: Theory and practice. Hoboken, NJ:
Wiley.
Terrell, F., & Terrell, S. (1984). Race of counselor, client, sex, cultural mistrust level and premature
termination from counseling among Black clients. Journal of Counseling Psychology, 31, 371–375.
Thompson, V. L. S., Bazile, A., & Akbar, M. (2004). African Americans’ perceptions of psy-
chotherapy and psychotherapists. Professional Psychology: Research and Practice, 35, 19–26.
Thorn, G. R., & Sarata, B. P. (1998). Psychotherapy with African American men: What we know
and what we need to know. Journal of Multicultural Counseling and Development, 26, 240–253.
Utsey, S., Ponterotto, J., & Porter, J. (2008). Prejudice and racism, year 2008—Still going strong:
Research on reducing prejudice with recommended methodological advances. Journal of
Counseling & Development, 86, 339–345.
Watson, Z. E., Herlihy, B. R., & Pierce, L. A. (2006). Forging the link between multicul-
tural competence and ethical practice: A historical perspective. Counseling and Values,
50, 99–107.

Counseling and Values ■ April 2014 ■ Volume 59 123

ACACVJ_v59_n1_0414TEXT.indd 123 3/13/2014 11:55:45 AM

 Welfel, E. R. (2006). Ethics in counseling and psychotherapy: Standards, research, and emerging issues
(3rd ed.). Pacific Grove, CA: Brooks/Cole.
Yosso, T. J. (2005). Whose culture has capital? A critical race theory discussion of community
cultural wealth. Race, Ethnicity, and Education, 8, 69–91.
Zhang, N., & Burkard, A. W. (2008). Client and counselor discussions of racial and ethnic dif-
ferences in counseling: An exploratory investigation. Journal of Multicultural Counseling and
Development, 36, 77–87.

124 Counseling and Values ■ April 2014 ■ Volume 59

ACACVJ_v59_n1_0414TEXT.indd 124 3/13/2014 11:55:45 AM

Copyright of Counseling & Values is the property of Wiley-Blackwell and its content may not
be copied or emailed to multiple sites or posted to a listserv without the copyright holder's
express written permission. However, users may print, download, or email articles for
individual use.