Jacoves v. United Merchandising Corp

In Jacoves v. United Merchandising Corp. (1992) 9 Cal.App.4th 88, the court determined the parents of a young adult who committed suicide stated a cause of action seeking emotional distress damages for negligence against a hospital that had treated their son. The court determined the hospital owed a direct duty to the parents because, inter alia, the parents were "active instrumentalities in their son's treatment," and the hospital's doctors "'treated the family in a family session weekly'" in which the parents "were intended to benefit from their participation in group therapy with their son." (Id. at pp. 109-110.)