Case Study: Tarasoff v. Regents of the University of California

Instructor: Ashley Dugger

Ashley has a JD degree and is an attorney. She has taught and written various law courses.

Usually, there is no legal duty to warn someone of an impending danger. However, sometimes a special relationship can change that duty. This lesson explores the 'Tarasoff Rule' and liability imposed on mental health professionals.

The Facts of the Case

In 1969, Prosenjit Poddar was a college student at the University of California, Berkley. He became enamored with fellow student Tatiana Tarasoff, but grew angry and depressed when Tarasoff rejected him. He sought emergency psychological treatment at the University hospital, where he was seen on seven occasions over the course of about 10 weeks.

During Poddar's seventh appointment, he told his psychiatrist he intended to kill Tarasoff. Poddar was diagnosed as having an acute and severe 'paranoid schizophrenic reaction.' Doctors decided he should be committed to a psychiatric hospital and contacted University police. Campus police briefly detained Poddar, but released him after he agreed to stay away from Tarasoff.

Neither the campus police nor the University doctors followed up with Poddar. Neither organization warned Tarasoff or her family. Two months later, Poddar accosted Tarasoff in her home. He shot her with a pellet gun, then chased her into the street and stabbed her to death with a kitchen knife.

Tarasoff v. Regents of the University of California

Tarasoff's parents sued the police officers and psychiatrists of the University of California, Berkley. The Tarasoffs alleged two causes of action, or reasons why the University should be held legally liable. They were:

  • The University did not confine Poddar.
  • The University did not warn Tarasoff or her family.

Initially, the Tarasoff family's lawsuit failed. Both the trial court and the California Court of Appeal ruled that the Tarasoffs did not have a valid cause of action. They ruled that the University did not owe a duty of care to Tarasoff. A 'duty of care' is an important legal term. It represents a responsibility, or legal obligation, to act in a way that avoids harming other people.

Generally, you have a legal duty to avoid unreasonably dangerous behavior that can cause foreseeable harm. For instance, you can't dig large, unmarked holes on a public playground. You can't throw rocks at passing cars. You can't cut down a large tree that is likely to fall on a neighbor's home. If you reasonably know - or should have known - that someone else would be harmed, then you had a legal duty to refrain from the behavior.

The Tarasoff family used this same 'duty of care' argument to assert that the University had an affirmative duty to detain Poddar and warn Tarasoff. They argued that, because it was easily foreseeable that Poddar would harm Tarasoff, the University had a legal duty to act in order to avoid that harm.

But the first two courts disagreed. They ruled that the Tarasoffs did not have a valid cause of action, since there was no duty of care placed on the University employees for Poddar's behavior. They ruled that there was no legal duty to act in order to avoid someone else's harmful behavior.

Special Relationship Exception

The Tarasoffs appealed to the California Supreme Court, who ultimately reversed the lower court rulings and allowed the Tarasoffs to amend their lawsuit to better present a valid cause of action. The state supreme court ruled that sometimes, in special circumstances, a party has a legal duty to act in order to avoid someone else's harmful behavior. This is known as the special relationship exception.

Here, the University doctors had a duty of care to Tarasoff resulting from Poddar's dangerous behavior. However, the police officers did not. The psychiatrists' duty of care was based on their 'special relationship' with Poddar. Communications between a therapist and a patient are generally considered to be confidential. Therapists can't usually disclose those communications. However, because psychiatrists are professionally trained to determine when a patient is a serious danger to others, psychiatrists are expected to use that special training to the benefit of the public.

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