In three recent cases, hereinafter referred to as the driving cases, the courts have taken up the issue of whether a psychotherapist should be held liable for negligent diagnosis and treatment and failure to warn third parties of a patient's potential danger to others in the operation of an automobile. These cases will be discussed as (1) an extension of the Tarasoff decision, which established psychotherapists' duty to protect third parties from patients' violent acts, and (2) what some commentators regard as a move toward holding the mental health professions to a standard of strict liability. How far have the courts in these cases extended the Tarasoff duty to protect and is the specter of strict liability real or imagined? This review finds the court adhering to a professional negligence standard as altered by the Tarasoff case in which the court applied the Restatement of Torts (Second) section 315 and held that the psychotherapist-patient relationship is a special relationship requiring a duty to protect or warn. And while a negligence standard ostensibly applies, the conclusions reached in these cases reveal an undeniable trend toward results one might expect to accrue under a strict liability standard.