Another Former Patient Sues Alsana Castlewood Treatment Center & Brittney Gibbs in Federal Court

FRAUD by non-disclosure included in the complaint

Case: 4:22-cv-00247

Filed 02/28/22

CARLA DOE vs. CASTLEWOOD TREATMENT CENTER, LLC d/b/a ALSANA, and BRITTNEY GIBBS

Full .pdf file of the complaint filed in Federal Court is available for download here:

Excerpts include:

This is an action for substantial and irreparable physical, emotional, and psychological harm that Gibbs – and her employer, Castlewood - perpetrated on Plaintiff during the course of what was to have been life-saving treatment for an eating disorder. It is predicated on theories of negligent hiring, supervision, and training, negligent and intentional infliction of emotional distress, negligence, and fraud by non-disclosure.

Castlewood employed Gibbs to serve as a therapist in or about May 2021. However, Gibbs does not have a license as Social Worker, Professional Counselor, Occupational Therapist or any other profession. And yet, Castlewood allowed Gibbs to have access to, and provide individual counseling to patients, including Plaintiff. Upon information and belief, Castlewood did so without performing any substantive background check on Gibbs. Had they simply searched Gibbs’ public and readily accessible social media postings, they would have discovered a series of disturbing blog articles written by Gibbs on her then Twitter feed.

The content of those articles is deeply disturbing, especially in light of the fact that Castlewood subsequently placed Gibbs, with little or no supervision, in a vital and authoritative position of trust with the most vulnerable of all populations of patients. Gibbs’ now-deleted articles included the following statements:

"Fuck love. Love hurts. Get a hobby."
"I reflected and realized I hurt others on purpose because it makes me feel good." ...
"There's a darkness in me ..."
"I can be toxic to the people I love."
"I participated in the toxic behaviors I didn't know any better, and sometimes I knew better but did not care."
"But, some days I hate myself, and I cause hell in other people's lives."
"One day I won’t say things to people strictly to hurt them."
“I became strong built from rage, and hate.”
“My mother hates me.” “The relationship with my mom now … Well she lives four houses down, and cant [sic.] look at me passing by. “I have one sibling out of 4 that [sic.] communicate [sic.] with me. Yes, that’s her manipulation.”
“My mom looks at me with such hatred I start to look at myself with the same view.”
“I didn’t receive a call from my mother apologizing, or asking how I’m doing. She strictly cut me from her life as if I was the umbilical cord."

The “therapy” Gibbs provided Plaintiff included showing her videos Gibbs had seen on TikTok. Gibbs even showed Plaintiff her personal TikTok posts. Gibbs advised Plaintiff that no one would know if she (Plaintiff) “followed” Gibbs, but that she (Gibbs) wouldn’t “follow” Plaintiff back while she was still a patient in case someone was able to see that and get her in trouble.

Gibbs further stated that she thought Castlewood’s program was “horrible” and that she was only planning to be there to get the hours needed for her license and try to make some changes to the program and then she would leave.

Gibbs talked negatively about other clinicians at Castlewood and disclosed details about their personal lives and why Gibbs believed they act the way they do, and that Plaintiff and others shouldn’t trust them.

Gibbs further stated that she reads books and does research to try to find ways to have power over people, how she had figured out everyone else who works at Castlewood and how she can manipulate them into doing what she wants. She even went so far as to say she wouldn’t send her own daughter to Castlewood if she needed help.

Gibbs also stated that she just wished she could be friends with Plaintiff outside of therapy. Gibbs stated that she doesn’t follow all of the rules and she still talks to some of the kids that she worked with from her previous job. Gibbs told Plaintiff and others to lie and say that Plaintiff could get her phone at night for spiritual reasons because if Plaintiff said that then she would be allowed to have it when other patients weren’t. Gibbs confirmed that she could find ways around anything.

On Friday, December 17, 2021, Plaintiff’s counsel discovered that despite having actual knowledge of Gibbs’ predatory nature, Castlewood stood behind and supported Gibbs by retaining her as an employee. A predator employee conducting group sessions. A predator employee conducting individual sessions. A predator employee with access to persons suffering from the mental illness with the second-highest mortality rate among all mental illnesses.

Plaintiff’s claims against Gibbs resulted in the discovery of an avalanche of additional issues and reprehensible conduct perpetrated by other Castlewood employees. On January 26, 2022, Gayle Devin, the current CEO of Castlewood issued a press release admitting that Castlewood “recently learned that … direct care employees might have been involved in inappropriate conduct involving a client receiving outpatient care at our St. Louis program. Based on our initial review, the allegations involve significant violations of company policy, and we have taken immediate action, including terminating employees and removing employees who remain under investigation from any client setting.”

Gibbs is simply one of the latest chapters in what has been the sordid and shameful history of Castlewood. This history includes, but is not limited to:

A series of lawsuits brought by Lisa Nasseff and others against Castlewood and its founder, Schwartz accusing Schwartz of implanting false memories of sexual abuse, satanic cult activity, brainwashing and hypnosis that ultimately led to the resignations of Schwartz and Galperin.
Accusations of Castlewood having violated the Americans with Disabilities Act brought by a woman who had a serious eating disorder, who allegedly was promised, but ultimately denied admission because she was HIV+ - claims that were successfully prosecuted by the United States Justice Department.
The Missouri Committee of Psychologists 2017 censure of Schwartz after a patient complained in 2013 about a lack of supervision at Castlewood, the investigation into which revealed that while Schwartz and Galperin were directors at the Masters and Johnson Trauma units at Two Rivers Psychiatric Hospital in Kansas City and also at River Oaks Hospital in New Orleans, lawsuits were filed against these hospitals for implanting memories of multiple personality and satanic ritual abuse;
Castlewood’s hiring in April 2013 of Nicole Siegfried, who, for at least the nine (9) months prior to her being hired, had been investigated by the Alabama Board of Examiners in Psychology and placed on probation and practice supervision for one year for ... "failure to document professional work and maintain records and engaging in a multiple relationship, patient harm and exploitive relationship;”
Accusations by a current Castlewood employee in July 2021, that: “Leadership is very inexperienced. Due to high turnover [sic.] and difficulty [sic.] with finding qualified applicants in the surrounding area, there have been quite a few internal transitions that are not effective. Newly licensed individuals can/have become part of leadership or promoted within leadership without leadership experience! Those with lesser experience do not feel confident in receiving feedback from those who, frankly. barely know what they are doing themselves. There is a push toward only one or two modalities of treatment (IFS and attachment theory), with little insight or training to other effective modalities. There is also very little understanding of the impact of comorbid or co-occuring diagnosis on eating disorders, thereby lessening [sic.] the effectiveness of the treatment;
Blatant misrepresentations regarding its treatment protocol and the efficacy of the treatment afforded, specifically that its treatment regimens are “evidenced-based”, when, in truth, they are anything but;
In January 2021, being sued for violating HIPAA laws;
Creating and fostering a racially hostile environment in which African American patients are denigrated.

Gibbs, as an alleged therapist providing therapy and counseling occupied a special place of trust and confidence and owed to Plaintiff a fiduciary duty and a high place of trust. However, Gibbs breached her fiduciary duties and intentionally inflicted emotional distress upon Plaintiff.

Gibbs’ above-mentioned conduct was so outrageous in character and so extreme in degree, as to go beyond all possible bounds of decency, was atrocious, and utterly intolerable in a civilized community. In a horrific attempt to assuage her own demons, insecurities and self-loathing, Gibbs hunted for future victims onto whom she could transfer her own rage and hatred. With malice aforethought, Gibbs sought to hurt Plaintiff in the worst possible manner … by destroying Plaintiff and Plaintiff’s family.

Gibbs knew that Plaintiff was particularly susceptible to emotional distress. As such, Gibbs knew or should have known that her conduct involved an unreasonable risk of causing the injuries and damages sustained by Plaintiff.

Castlewood’s conduct clearly evidences an evil motive or reckless indifference or Castlewood’s conduct was outrageous. Castlewood placed its emphasis on generation of profits for its private equity owner. Castlewood compromised treatment standards and misrepresented both its treatment protocols and the efficacy of those protocols. Castlewood intentionally harmed Plaintiff without just cause or acted with a deliberate and flagrant disregard for the safety of Plaintiff. Accordingly, Castlewood’s conduct justifies an award of punitive damages against Castlewood in an amount adequate to punish the wrongful conduct alleged herein and to deter such conduct in the future.

Castlewood clearly had the duty to not expose Plaintiff nor its patient population to a reprehensible predator. Castlewood violated that duty by employing as a therapist, a person suffering from anti-social personality disorder. Similarly, Castlewood’s lack of supervision was so lax, that is if it wasn’t’ non-existent entirely, resulted in its CEO admitting that it was investigating other employees for abusive conduct.

Castlewood not only had actual knowledge of but created and facilitated a dangerous condition on its property, to wit: allowing predators, including inexperienced, untrained and inappropriate employees to have access to patients. Castlewood’s creation of the dangerous condition included, but is not limited to, the following acts and/or omissions:

A. not allocating sufficient financial resources to investigate, hire and train competent, professional mental health providers;

B. hiring a person with anti-social personality disorder to act in the role of a trusted counselor;

C. failing to investigate Gibbs before employing her in the role of a trusted counselor;

D. failing to adequately train Gibbs;

E. failing to properly supervise Gibbs;

F. failing to provide a safe environment where Plaintiff would be free from abuse and the actions of predators; G. failing to protect Plaintiff from harmful predators like Gibbs.

Fraud By Non-Disclosure

On January 3, 2017, Riverside acquired Castlewood from its former private equity owner, Trinity Hunt Partners. As previously noted, Castlewood at that time was, and remains a deeply troubled institution.

To attempt to separate itself from its troubling past issues, Castlewood changed its name to Alsana. Castlewood Treatment Center, LLC filed and registered the fictitious name, Alsana with the Missouri Secretary of State on March 28, 2019.

To further cover up its past, Castlewood changed all Castlewood references on the internet to “Alsana.” This was done with the intent of making Alsana appear to be a reputable treatment center which had been in operation for several decades. Castlewood altered hundreds of press releases on Castlewood’s website. These press releases constitute and establish a pattern of false statements pertaining to health care matters and were made with the intent to defraud Plaintiff, and other third parties.

The blog section on “Alsana’s website” lists 49 pages, with 12 articles on each page which laud the alleged work performed by “Alsana.” These articles go back to 2011, 8 years before Alsana’s Fictitious Name Certificate was filed. See, https://www.alsana.com/blog. Castlewood’s name does not appear on any of the 588 articles.

In addition, months before the Alsana fictitious name was registered, a number of Castlewood employees appeared in videos broadcast on the YouTube platform espousing the merits and qualities of Alsana, an entity which then did not exist. These communications were made with the intent to defraud Plaintiff, and other third parties.

On its website, Castlewood advertises that it uses “holistic, evidence-based eating disorder treatment.” The purpose of this statement is to entice patients to come to its treatment facilities. But nothing could be further from the truth. Castlewood allegedly utilizes what it refers to as “Adaptive Care Model.” This Model allegedly reflects its “integrative approach to eating disorder treatment. We focus on the total health and well-being of each client by empowering these areas: medical, therapeutic, nutrition, movement, and relational practices.”

In order to lure patients to its facilities, Castlewood represents that its “Adaptive Care Model outperforms traditional eating disorder treatment models in reducing the severity of eating disorder symptoms.” However, no university-based, governmental agency, third party, peer-reviewed, or independent agency-based research study exists indicating that Castlewood’s Adaptive Care Model is effective or appropriate in treating eating disorders. Further, the survey relied upon by Castlewood is forced upon its patient population while they are receiving treatment. If a patient does not submit her weekly survey, Castlewood withholds treatment until such time as the survey is filled out and turned in.

Castlewood also allegedly uses treatment regiments known as “Internal Family Systems” (“IFS”) and Dissociative Identity Disorder Therapy (“DID”). Again, no reputable residential treatment program in the United States utilizes these treatment programs.

Castlewood discovered that it could make far greater profits for its owner by repeatedly treating patients who relapse, without being held accountable for outcomes. As such, Castlewood created an eating disorder treatment program that is outside any reasonable or logical standard of care, and which resulted in a revolving door of patients.

Castlewood, as the provider of medical and mental health treatment of eating disorders, had the legal, moral, ethical, social and fiduciary duty to Plaintiff to disclose all material facts pertaining to its operations. As such, Castlewood’s acts, conduct, omissions and misrepresentations constitute fraud by non-disclosure which was the proximate and producing cause of Plaintiff’s damages.