In Palmer v Tees Health Authority, the claimant argued that a local Mental Health Authority owed her a duty (and had, subsequently, breached this duty) in allowing a psychiatric patient into the community without adequate supervision. The patient had previously threatened to kill a child and subsequently attacked and killed the claimant’s daughter. The Court of Appeal, following Hill, stated that there was not sufficient proximity between the parties for a duty to exist. She was not an identifiable potential victim and there was nothing that the defendants could have reasonably done to prevent the incident occurring.