Transference refers to unconscious feelings transferred from the past to persons in the present. Countertransference occurs when a therapist experiences unconscious conflicts and feelings toward a patient. Some sexual relationships between patients and therapists are attributed to transference and countertransference gone awry; others, to emotionally disturbed therapists. Civil law has not always found transference and countertransference a mitigating factor for either patient or therapist, as illustrated by two cases. Damages resulting from a therapist's sexual relationship with a patient are reviewed, and six-figure judgments are shown to be common following Roy v. Hartogs in 1976. The awards are large because patients are often devastated by such experiences and may suffer a severe regression requiring hospitalization. Also discussed are possible defenses that could have been raised in Roy v. Hartogs, and the possibility of a therapist becoming involved in licensure and criminal proceedings as well as in civil litigation. Included are 29 notes.