Tarasoff v. Regents of the University of California Case Brief: Duty to Warn in Mental Health Law

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

Citation

Tarasoff v. Regents of the University of California, 17 Cal.3d 425 (1976)

Court

California Supreme Court

Facts

The case arose from a tragic incident in which Tatiana Tarasoff was murdered by Prosenjit Poddar, a former student at the University of California, Berkeley. Poddar had expressed his intentions to kill Tarasoff to his therapist, Dr. Lawrence Moore, at the university's counseling center. Although Dr. Moore assessed Poddar as dangerous and recommended that campus police detain him, the police did not act on this recommendation. Instead, Poddar was released after a brief evaluation. He subsequently killed Tarasoff. Her family sued the Regents of the University of California, alleging that the university and its employees had a duty to warn Tarasoff of the threat to her life.

Issue

Does a mental health professional have a duty to warn a potential victim when a patient expresses a serious intent to harm that individual?

Rule

In California, mental health professionals have a duty to take reasonable steps to protect third parties when they are aware of a credible threat to that individual’s safety.

Application

The California Supreme Court held that a therapist has a duty to warn potential victims when they have knowledge of a specific threat against them. The court ruled that this duty arises when a therapist determines that a patient poses a serious risk of harm to an identifiable victim. The court acknowledged the balance that must be struck between patient confidentiality and the safety of potential victims.

In this case, the court found that Dr. Moore failed to warn Tarasoff despite knowing of Poddar’s intentions. The court emphasized that the need to protect individuals from harm outweighed the principle of confidentiality in therapeutic relationships.

Conclusion

The California Supreme Court's decision in Tarasoff v. Regents of the University of California established the "duty to warn" precedent, requiring mental health professionals to take action to protect third parties when they are aware of threats posed by their patients. This case has had a profound impact on mental health law and the ethical obligations of therapists in California and beyond.