Many malpractice suits are brought not because of malpractice nor even because of complaints about the quality of medical care but as an expression of anger about some aspect of patient-doctor relationships and communications. The theory presented is that under the stress of anxiety and physical illness, some patients regress to childhood needs; physicians are not generally trained to fill such needs. Thus, these patients, angry because of this, express their anger in malpractice suits. This theory has been taught to physicians and medical students as part of a physician continuing medical education (CME) seminar on Loss Prevention/Risk Management through demonstration of active-listening techniques to seminar participants. Physicians who understand and can respond appropriately to the emotional needs of their patients are less likely to be sued. This may also translate into a more fulfilled practice of medicine by those physicians who are most aware of the importance of a positive relationship.