Should courts recognize a broader rule for creating a duty, capable of encompassing wrongful communications? Plaintiff was molested by a school administrator. The administrator had a past history of sexual misconduct. This history was known to individuals who had recommended him for the position he occupied when the incident with the plaintiff occurred. However, those individuals did not include this information in their letters. In her lawsuit, the plaintiff sued the recommenders, on the theory that it was negligent for them to withhold information which could foreseeably lead to harm.