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Understanding the normative logic of such derivative actions opens up intellectual and conceptual space for doing practical justice elsewhere in tort law. Suppose that a therapist negligently treats his patient, a child, and thereby induces in her false memories of abuse at the hands of her parent. It is plain that the child may recover from the therapist, but may the parent? Courts that have addressed such cases are split. Some recognize a duty of care to the patient’s parent; others do not.226 All of these courts agree that whether the parent may recover turns on whether the therapist owes a duty of care to her, on top of the duty of care inarguably owed to her child.227