Mrs. Roe, who was separated from her husband and living with her minor child, was in ongoing psychotherapy with a psychologist. Mrs. Roe made certain disclosures to the psychologist regarding child abuse by Mr. Roe. The psychologist, under California's child abuse reporting statute, reported this suspected abuse to the California Department of Children's Services. The filing of the report prompted an investigation that resulted in an escalation of the conflict between Mr. and Mrs. Roe. Mr. Roe filed suit against Mrs. Roe for "defamation, malicious prosecution, negligent and intentional infliction of emotional distress, negligence, interference with visitation rights, and conspiracy." The court held that the psychologist could be ordered to reveal statements made by Mrs. Roe which triggered the filing of a child abuse report against Mr. Roe. Under California's Child Abuse and Neglect Reporting Act, Mrs. Roe's psychologist had no choice about filing a report, no matter what could happen to Mrs. Roe and her child as a result of the report. In discussing the elements of the "Roe" decision that present ethical and practical dilemmas for psychotherapists, this article discusses informed consent for treatment that includes awareness of mandated child abuse reporting and the possibility that a client may manipulate the reporting mandate to harm others. The author concludes that further study by social policymakers and research on the impact of mandated reporting on the reporters' professional role and on the lives of families who are investigated is needed, so as to address the dilemmas raised in "Roe" and related court decisions. 11 notes and 28 references