Stecks v. Young
California Court of Appeal
38 Cal. App. 4th 365, 45 Cal. Rptr. 2d 475 (1995)
- Written by Liz Nakamura, JD
Facts
Candace Young (defendant), a licensed counselor with a doctorate in clinical psychology, treated the 29-year-old, schizophrenic daughter (the patient) of David and Nancy Stecks (plaintiffs). During a counseling session with Young, the patient alleged that her parents had abused her as a child and had subjected her to cult rituals. The patient also claimed that her nephew, the Steckses’ grandson, was scheduled to be sacrificed as part of a fall equinox ritual. Without speaking to the Steckses, the nephew, or the nephew’s parents, Young reported the patient’s allegations to Child Protective Services (CPS). Young’s report was based entirely on the patient’s accusations. The Steckses sued Young for libel, slander, and intentional infliction of emotional distress, arguing that the accusations in Young’s report were false and that Young filed the report in the absence of reasonable suspicion. Young demurred and moved to dismiss, arguing that she had absolute immunity because she was a mandated reporter. The trial court sustained Young’s demurrer and entered a judgment in Young’s favor. The Steckses appealed.
Rule of Law
Issue
Holding and Reasoning (Haller, J.)
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