7

The courts generally have interpreted “reasonable cause to believe” very liberally, thereby reducing the risk of being sued for making a report that turns out to have been false. See, e.g., Cream v. Mitchell, 264 Cal. Rptr. 876 (Cal. App. 1989) (a doctor who misdiagnosed chicken pox as venereal disease, and reported his diagnosis to the state, was found to have had a reasonable suspicion of abuse); Thomas v. Chadwick, 274 Cal. Rptr. 128 (Cal. App. 4 Dist. 1990) (a doctor who misdiagnosed a congenital defect as child abuse, and who reported his diagnosis to the state, was immune from liability).