Court found that a mental health professional has a duty not only to a patient but also to individuals who are specifically being threatened by a patient. This decision has since been adopted by most states in the U.S. and is widely influential in jurisdictions outside the U.S. as well. Justice Mathew O. Tobriner wrote the holding in the majority opinion. "We conclude that the public policy favoring protection of the confidential character of patient-psychotherapist communications must yield to the extent to which disclosure is essential to avert danger to others. The protective privilege ends where the public peril begins." Justice Mosk wrote a partial dissent, arguing that (1) the rule in future cases should be one of the actual subjective prediction of violence on the part of the psychiatrist, which occurred in this case, not one based on objective professional standards, because predictions are inherently unreliable; and (2) the psychiatrists notified the police, who were presumably in a better position to protect Tarasoff than she would be to protect herself. Justice Clark dissented, quoting a law review article that stated, "…the very practice of psychiatry depends upon the reputation in the community that the psychiatrist will not tell." Reception Some decried the court's decision as a limitation of the foundation for the therapeutic relationship and progress, the client's expectation of confidentiality. In 1979, Max Siegel, a former president of the American Psychological Association, defended the therapist's right to confidentiality as sacrosanct, under any circumstances. Furthermore, he suggested that had Poddar's psychologist maintained confidentiality, instead of alerting the police, Poddar might have remained in counseling and Tarasoff's death might have been averted through Poddar's psychological treatment. Subsequent developments As of 2012, a duty to warn or protect is mandated and codified in legislative statutes of 23 states, while the duty is not codified in a statute but is present in the common law supported by precedent in 10 states. Eleven states have a permissive duty, and six states are described as having no statutes or case law offering guidance. Despite initial commentators' predictions of negative consequences for psychotherapy because of the Tarasoff ruling, court decisions show otherwise. An analysis of 70 cases that went to appellate courts between 1985 and 2006 found that only four of the six rulings in favor of the plaintiff cited Tarasoff statutes; courts ruled in favor of the defendant in 46 cases and sent 17