Emerich v. Philadelphia Center for Human Development, Inc.
Supreme Court of Pennsylvania
720 A.2d 1032 (1998)
Therapist Scuderi (defendant) treated both Hausler and her boyfriend Joseph, whom Scuderi knew had a history of abusing Hausler and diagnosed with serious personality disorders, and after Joseph called Scuderi to say he intended to kill Hausler and repeated that intent during an emergency session, Scuderi warned Hausler not to go to their old apartment and to leave town, but she ignored the warning and was shot and killed by Joseph upon returning; her estate administrator sued Scuderi and his clinic, and the trial court dismissed on the pleadings.
Whether a therapist owes a duty to exercise reasonable care to protect a third party by warning that person of a specific and immediate threat of serious bodily injury targeted at the person by a specific individual who is in a treatment relationship with the therapist.