Card v. Blakeslee
In Card v. Blakeslee, 937 P.2d 846 (Colo. App. 1996), a therapist sent a letter to her patient expressing an opinion that the patient should not have any contact with her "family of origin." The letter was addressed "to whom it may concern."
The patient's mother, relying on Montoya v. Bebensee, asserted a claim against the therapist for negligent infliction of emotional distress.
In affirming the trial court's dismissal of the mother's claim, a division of this court stated that, unlike the circumstances in Montoya, the mother had failed to allege that the therapist published a public report or recommendation, and had failed to allege the issuance of an opinion accusing plaintiff of abuse. Card v. Blakeslee, supra.