Commonwealth v. Peterson
Supreme Court of Virginia
749 S.E.2d 307 (Va. 2013)
After an initial, apparently isolated shooting at one Virginia Tech dormitory, police from three agencies told university officials the shooter had fled and posed no further danger; based on that information, officials sent only a general caution email before a second, unrelated mass shooting later that morning killed several students, including Erin Peterson and Julia Pryde. Their estates sued Virginia Tech for wrongful death, and the circuit court found a special relationship existed imposing (and breaching) a duty to warn, prompting the Commonwealth's appeal.
Whether, even if a special relationship exists, there is a duty to warn of an unknown or unforeseeable danger of third-party criminal acts.