Ryder v. Mitchell

In this case, we must determine whether a child therapist owes a duty of care to her patients' mother in a cireumstance in which she allegedly misdiagnosed symptoms of parental alienation and reported her findings to the father and to the children's new therapist. The court of appeals found that such a duty exists. Mitchell v. Ryder, 20 P.3d 1229, 1233 (Colo.App.2000). We disagree and now conclude that the duty the therapist owes the children themselves is primary and may, under certain cireumstances, require disclosure to the parents or other involved parties. Creating a duty to the parents…