Inc. v. Walk to Emmaus, 801 N.W.2d 193, 202 (Minn.Ct.App.2011) (stating that, “to impose liability under section 324A(b), one who undertakes a duty owed by another to a third person must completely assume the duty”); Plank v. Union Elec. Co., 899 S.W.2d 129, 131 (Mo.Ct.App.1995) (concluding that “one must intend to completely subsume or supplant the duty of the other party in order to incur liability for nonperformance of that duty”); Obenauer v. Liberty Mut. Ins. Co., 908 F.2d 316, 317 (8th Cir.1990) (concluding that an insurer providing safety services to a manufacturer was not liable under Section 324A to the user of a manufactured product because the insurer did not “replace” the manufacturer’s duty to design a safe product); Furek v. Univ. of Del., 594 A.2d 506, 515-16 (Del.1991) (<HOLDING>); Davis v. Liberty Mut. Ins. Co., 525 F.2d
recognizing that section 324ab applies only when one undertakes to supplant the duty of another owed to a third person recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person recognizing that negligent conduct of police investigations does not give rise to a cause of action because the duty to protect citizens and enforce the law is one owed generally to the public holding law enforcement owed duty similar to that owed by dshs under rcw 2644050 holding that a psychiatrist owed a duty to a person foreseeably injured by his patient