Cohen v. State

HAYS, Justice.

This case involves the constitutionality of legislation relating to the certification of psychologists practicing in Arizona. For reasons to be discussed, we hold that A.R.S. § 32-2071 and § 32-2072 are invalid because they are unconstitutionally vague and ambiguous.

Appellant Leonard M. Cohen (Cohen) holds a doctorate in social science (D.S.Sc.) awarded in 1948 by the New School of Social Research in New York. He also holds a master’s degree in psychology from the University of Pittsburgh earned in 1945. As directed by A.R.S. § 32-2071, Cohen applied for certification as a…