Roberts v. Salmi

In this suit for malpractice, plaintiffs, Lale Roberts and Joan Roberts, appeal by right the trial court’s order dismissing their claims against defendant, Kathryn Salmi, LPC, who does business as Salmi Christian Counseling. On appeal, we must determine whether a mental health professional, such as a licensed professional counselor, see MCL 330.1100b(16)(e); 333.18101(b),1 owes a duty of care to third persons who might be harmed by the professional’s treatment of his or her patients. Specifically, we must determine whether a mental health professional has a duty to third parties…