Mealey's (March 2, 2016, 12:01 PM EST) -- SAN FRANCISCO — The Ninth Circuit U.S. Court of Appeals on Feb. 24 affirmed a trial court ruling that a marriage and family therapist in an Ambien suicide case owed the decedent no duty to warn and was not properly joined as a defendant (Jennifer Kwasniewski, et al. v. Sanofi-Aventis U.S., LLC, et al., No. 13-17390, 9th Cir.; 2016 U.S. App. LEXIS 3217)....