"The Tarasoff duty arises whenever a therapist determines, or pursuant to the standards of the profession, should determine, that his or her patient presents a serious danger of violence to another. The court's approach thus shifts the inquiry from what an individual therapist actually believed to what a competent therapist ought to have believed. Courts typically evaluate conduct in this manner, making social judgments about the appropriateness of questioned behavior ... Nine out of ten [respondents] thought that the Tarasoff obligation applies both when a therapist actually believes someone is dangerous and also when a reasonable therapist would believe this. They understand correctly the court's statement in this regard.

Only about one out of four (slightly more for social workers) believed it applied whenever there was a threat. There are two ways of viewing this figure: with satisfaction that three out of four understand that Tarasoff is concerned with danger, not threats, or with distress that one out of four does not. The appropriate view the Tarasoff critics might suggest is probably the latter -- it is somewhat unsettling to find a substantial number of therapists who believe that threats per se should trigger a warning." [Daniel J. Givelbe, William J. Bowers and Carolyn L. Blitch, "Tarasoff, Myth And Reality: an Empirical Study of Private Law in Action," 1984 Wis. L. Rev. 443, 460-462].