Legal doctrines do not stand still, but instead evolve and tend to grow and to spawn what law school academicians fondly term progeny. Tarasoff is no exception. In an expanding list of court decisions, psychiatric patients are being convicted of crimes by virtue of actions by their psychiatrists or psychotherapists purportedly based on the duty to warn. One recent case has featured surreptitious evidence-gathering by a psychiatrist, the latest progeny of Tarasoff.