[quote=@Angel Eyes]

Also, empathic manipulation may not be effective against Jerome since his brain could potentially repair itself from an empathic push, since empathic manipulation would essentially manipulate certain chemicals in the brain to bring about a certain emotional effect. 
[/quote]

I wouldn't say so, after all, empathy manipulates emotions, which are natural reactions to stimuli. How would his healing factor know that the rage or fear or anger rushing through his system is in fact encouraged by the abilities of an empath? There's no actual damage there, just an emotion that he will have felt before. Otherwise it would react in exactly the same manner to any emotion and heal it away, leaving him little better than a robot who just happens to breathe.