a duty to exercise reasonable care when the actor’s conduct creates a risk of physical haim”). Although we agree with the court of appeals that Alger owed a duty of reasonable care to Sanders, we decline to adopt that court’s rationale, as we need not here decide whether people generally owe a duty of reasonable care to others. Cf. Gipson, 214 Ariz. at 146 ¶ 24 & n.4, 160 P.3d 228 (noting tension in Court’s statements regarding scope of duty and declining, as unnecessary, to base decision on broad statements of duty generally owed by all persons). ¶ 9 Under Arizona common law, duties of care may arise from, among other things, a direct relationship between the parties. Id. at 144-45 ¶ 18, 150 P.3d 228; see also Stanley v. McCarver, 208 Ariz. 219, 221 ¶ 7, 223 ¶ 13, 92 P.3d 849 (2004) (<HOLDING>); Ontiveros, 136 Ariz. at 508, 667 P.2d 200
holding that the physicianpatient relationship terminated when the patient missed a scheduled appointment and did not see the physician again and that the relationship did not continue despite the fact the patient later secured a refill of a prescription that was prescribed during the relationship holding that a physicianpatient relationship gives rise to a duty to avoid emotional harm from failure to provide critical information to patient holding that the evidence relied on by the insurer need not include the opinion of an examining physician recognizing duty by examining physician even absent formal physicianpatient relationship recognizing the tort of breach of physicianpatient privilege