In the landmark 1976 California case of "Landeros v. Flood", the California Supreme Court remanded a case to the trial court for action in tort against a treating physician for failure to report suspected child abuse. The theory at trial was that the plaintiff, a child of about 12 months of age, had been returned to a home where further physical abuse occurred, causing more damages. This was because the physician had failed to report the abuse in violation of California law. After this case, all states instituted mandatory reporting by physicians and other medical personnel of any suspected child abuse or neglect cases. In general, reporting in good faith shields the physician or health care worker from tort liability. Reporting to police or social services necessitates obtaining medical records by subpoena duces tecum. This case, and legislation that followed it were in response to several articles that appeared in the medical literature that defined "battered child syndrome" and "child abuse syndrome".