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Three state court decisions' have held that psychiatrists2 must warn potential victims of the violence threatened by their patients.' These decisions have created a new exception to the long-standing general rule, based on respect for individual liberty, that an individual is not required to take affirmative steps to rescue others from danger. These state court decisions justified overriding the liberty principle by extending the "special relationships" rationale for affirmative duties to the psychiatrist-patient relationship, and by the policy argument that imposing such a duty

Professional Obligation and the Duty to Rescue: When Must a Psychiatrist Protect His Patient's Intended Victim?