Is a therapist liable for failing to warn a potential victim of a threat made to the potential victim by a therapist's patient?

Hedlund v. Superior Court (1983) 34 Cal.3d 695, 194 Cal.Rptr. 805, 669 P.2d 41 involved the question where a psychotherapist was liable for injuries when he failed to warn a potential victim of a threat made to the victim by the therapist's patient. There, both plaintiff and the assailant had been patients, and the psychotherapist failed to warn the plaintiff of these threats. The assailant used a shotgun to inflict serious bodily injury upon the plaintiff. Her two year old son was seated next to his mother when she was shot, and she threw herself over him thereby saving his life. Although the court did not decide whether a duty existed as to all "bystanders" (id., p. 705, 194 Cal.Rptr. 805, 669 P.2d 41) the court reasoned that if it was foreseeable that a mother would sustain emotional injury witnessing an injury to her child, "...

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