Noah Keats Sall v. Jack M. Ringel, et al. Ringel was Keats’ therapist.
- In 2022, approximately three years after their last session, Keats e-mailed Ringel and requested his clinical notes. Keats then initiated a complaint against Ringel for negligent infliction of emotional distress and outrage, contending the clinical notes were fabricated and created only once Keats made the request. The trial court dismissed Keats’ claims after the jury found Keats failed to prove the notes were created in 2022. Keats appeals asserting the court erred in not giving a spoilation instruction and in giving a special verdict form regarding when the notes were created. COA #887092. King County Superior Court #23-2-16954-9.