‘Cuddling’ Therapy Case Against Psychotherapist Reinstated

California psychotherapist Scott Kazarian must answer claims he had inappropriate contact with a patient with whom he engaged in “cuddling” therapy, a state appeals court said.

Kimberly Neilsen’s medical liability claims were timely filed under a delayed discovery theory, the California Court of Appeal, Third District, said in an unpublished March 19 decision. The court reinstated Neilsen’s complaint because she didn’t realize that Kazarian’s 2013 treatment injured her until she began seeing another therapist in 2016, it said.

Neilsen went to Kazarian for treatment of depression and issues related to her adoption. Kazarian’s cuddling therapy involved full-body contact, Neilsen said. ...