who then killed his wife and her lover. The Supreme Court of Georgia agreed with the Georgia Court of Appeals’ articulation of the legal duty breached by the hospital: “where the course of treatment of a mental patient involves an exercise of ‘control’ over him by a physician who knows or should know that the patient is likely to cause bodily harm to others, an independent duty arises from that relationship and falls upon the physician to exercise that control with such reasonable care as to prevent harm to others at the hands of the patient.” Id. at 695-96. Other Georgia cases addressing the “special relationship” exception have likewise focused on the defendant’s degree of control. Compare, e.g., Associated Health Sys., Inc. v. Jones, 185 Ga.App. 798, 366 S.E.2d 147, 152 (1988) (<HOLDING>), with Trammel v. Bradberry, 256 Ga.App. 412,
holding that duty to protect from criminal acts does not arise in the absence of a foreseeable risk of harm holding that a party who can show a significant risk of irreparable harm has demonstrated that the harm is not speculative holding that a threat to harm another person is a crime of violence holding that nursing home owed duty not to subject resident to unreasonable risk of harm at hands of coresident with known propensity for violence holding that a defendants propensity to commit crime generally even if the resulting harm would be not solely physical may constitute sufficient risk of danger to come within contemplation of the bail reform act