Farwell v. Keaton, 396 Mich. 281, 240 N.W.2d 217 (1976)

Courts have been slow to recognize a duty to render aid to a person in peril. When such a duty has been found, it has been predicated upon the existence of a special relationship between the parties; in such a case, if defendant knew or should have known of the other person’s peril, he is required to render reasonable care under all circumstances. Such a defendant will then be liable for a failure to use reasonable care for the protection of the plaintiff’s interests.