Xavier once stated, that Empath is a very powerful psychic, but so is Emma.
And Miss Frost already had sort of a duell with Mister de la Rocha:
She was debating with him about the mistake he made in manipulating Warpath and Firestar to fight the X-men. In the end she mind-slapped him and he felt so embarressed by that, that he invaded her mind, made her love him and do everything he wants. BUT Emma overcame his influence, surprised him and blocked his brain, so that he wasn't able to use his powers anymore.
Question answered, i guess!
