v. United Hosps. Med. Ctr. Presbyterian Hosp., 153 N.J.Super. 79, 379 A.2d 57, 58 (App.Div.1977) (recognizing possibility of claim for relief based on violation of an implied contract with the hospital where parents alleged that hospital negligently informed them of the death of their child). 22 . Accord Freeman v. Harris Cnty., 183 S.W.3d 885, 890 (Tex.Ct.App.2006) (noting that ”[s]pecial relationship cases generally have three common elements: (1) a contractual relationship between the parties, (2) a particular susceptibility to emotional distress on the part of the plaintiff, and (3) the defendant’s knowledge of the plaintiff’s particular susceptibility to the emotional distress, based on the circumstances’’); but see Johnson v. Methodist Hosp., 226 S.W.3d 525, 530 (Tex.Ct.App.2006) (<HOLDING>). 23 . See generally Undertakings and Special
holding that mother who was misdiagnosed as being hiv positive during her eighth month of pregnancy and subsequently treated for hiv did not have a special relationship with the hospital that was responsible for the misdiagnosis and delivered her child holding that fundamental error occurred in the prosecution of a mother for aggravated manslaughter of her child when the prosecutor commented on the fact that the mother had contemplated having an abortion during the course of her pregnancy with the child holding that evidence was sufficient to support trial courts best interest finding where mother allowed child to be in contact with individual who had physically abused her mother was not capable of caring for child on her own mother admitted at trial she had not found stable employment and child was doing well in her current placement holding evidence that mother allowed child to remain in home in which there was violent conduct as evidenced by fathers physical abuse of mother during her pregnancy was legally sufficient to support termination holding mothers drug use during pregnancy and after child was removed from her care in face of random drug testing that placed her relationship with child at risk was legally and factually sufficient evidence that she engaged in course of conduct which endangered her child