L.A.R. v. Ludwig

In L.A.R. v. Ludwig, 170 Ariz. 24, 28, 821 P.2d 291, 295 (App. 1991), the Court concluded the trial court did not err in finding a counselor had "reasonable grounds" to report child sexual abuse. Id. at 26-27, 821 P.2d at 293-94. The Court based our decision on the public policy consideration "of encouraging people to report child abuse." Id. at 27, 821 P.2d at 294. Based on the facts in Ludwig, the Court cannot say the trial court erred in granting summary judgment in favor of Sheets. In Ludwig, the trial court found a counselor had "reasonable grounds" to believe a child had been sexually abused by her father based simply on a statement from the child's mother. Id. at 26, 821 P.2d at 293.