Dudley v. Offender Aid and Restoration of Richmond, Inc
In Dudley v. Offender Aid and Restoration of Richmond, Inc., 241 Va. 270, 401 S.E.2d 878, 7 Va. Law Rep. 1686 (Va. 1991), a private halfway house accepted a convicted felon for residence under a contract with the Virginia Department of Corrections.
Inmates were permitted to leave during the day, but the halfway house was required to monitor their whereabouts.
One night, an inmate left the house, broke into a nearby apartment, and strangled a woman to death. Holding that the halfway house owed a duty to the victim, the Virginia Supreme Court wrote that the scope of the duty varied with the circumstances of each case.
If the defendant "takes charge" of a person who is dangerous only to a specific individual, the defendant's duty runs "only to that individual because the risk of injury from a breach of the duty would be foreseeable only as to that prospective victim." 401 S.E.2d at 883.
But the court observed that the duty would more often run to all reasonably within the reach of the dangerous person. Id.