The Jablonski case addressed the need for mental health professionals to consult prior records to determine dangerousness. In the Bradley Center case, the hospital’s duty to protect was breached by the negligent release of a dangerous patient who subsequently carried out his threat to kill a readily identifiable person. The ruling determined that the mental health professionals had a duty to ensure that a dangerous person was not released. The Tarasoff case was the beginning of the Duty to Warn/Duty to Protect cases. It’s ruling was that counselors have a duty to take reasonable care to protect the intended victim. The Hedlund case addressed that duty to warn extends beyond the named victim to anyone else who might reasonably be at risk (in the actual case, it was the victim’s child).