to perform his undertaking, if (a) his failure to exercise such care increases the risk of such harm, or (b) the harm is suffered because of the other’s reliance upon the undertaking.’ ” Frye, 153 Ill. 2d at 32, quoting Restatement (Second) of Torts §323 (1965). Courts narrowly construe the theory, however, and limit the scope of the duty to the extent of the undertaking. Buerkett v. Illinois Power Co,, 384 Ill. App. 3d 418, 427-28 (2008). For example, the Chicago Housing Authority, in voluntarily hiring a security company to patrol the premises, did not assume a duty to protect the decedent, a social guest, from criminal conduct and could have been liable at most for negligent hiring. Pippin v. Chicago Housing Authority, 78 Ill. 2d 204, 209-10 (1979); see also Frye, 153 Ill. 2d at 34 (<HOLDING>). We reject the Gattos’ argument that State
holding that a failure to warn was not a policy judgment holding that the defendant pharmacist had undertaken a duty to accurately warn of a drugs side effects with respect to the warning actually given but not a duty to warn of all possible side effects of the medication holding that a pharmacist has a duty to warn when he or she knows of a risk to that particular customer holding that the court had no duty to warn defendants about the possibility of deportation as a collateral consequence of conviction holding that a failure to warn is a discretionary function and that ftjhe very paucity of proof concerning the possible deleterious effects of agent orange made the decision whether to issue a nationwide health warning even more clearly an exercise of discretion