Mower v. Baird, 2018 UT 29 (July 11, 2018)

The district court granted summary judgment to the defendant therapist, concluding that the therapist did not owe a duty to the non-patient parent who sued her.  The supreme court reversed this decision and remanded for further proceedings, holding that a treating therapist working with a minor child owes a limited duty to a non-patient parent to refrain from affirmative acts that recklessly violate the standard of care in a manner that gives rise to false memories or false allegations of sexual abuse committed by the non-patient parent.