Tieqiao (Tim) Zhang v. Emory University, 23-12365

Albert Zhang, a minor and Emory University student, died by suicide after experiencing academic pressure, relationship difficulties, and homelessness.
His parents (Liang and Zhang) filed a negligence suit against Emory, arguing the university had a special duty of care given their son's age, warning signs, and Emory's awareness of suicide risks.
The district court dismissed their claims with prejudice, finding the facts insufficient to show Emory staff could reasonably foresee Albert's suicide, as required by Georgia law.
The appeal challenged both the admission of evidence outside the complaint at the motion-to-dismiss stage and the sufficiency of the complaint to allege a plausible claim for relief.
The court analyzed whether Emory owed a duty, breached it, and whether Albert’s suicide was a foreseeable result under established exceptions to liability for suicide under Georgia law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consideration of docs outside complaint	District court should exclude or provide discovery if considering outside docs	Email and police report are central, undisputed, and quoted in complaint	No error in considering; incorporated by reference
Sufficiency of foreseeability allegations	Complaint plausibly alleged Emory should've foreseen suicide, especially given context	No plausible facts show Emory could/should have foreseen imminent risk	Facts insufficient for plausible foreseeability
Special relationship/duty to disclose	Emory, knowing Albert’s status and risk factors, had special duty to intervene	Even if such a duty existed, foreseeability not shown	Did not reach duty; assumed arguendo and found no foreseeability
Negligence per se/other new theories on appeal	Emory liable under Title IX or "health emergency" (raised late)	Such theories not pleaded below; proximate cause still required	Proximate cause/foreseeability not met, even negligence per se

City of Richmond Hill v. Maia, 800 S.E.2d 573 (Ga. 2017) (Georgia's heightened liability and exceptions regarding suicide as unforeseeable intervening cause)
Rasnick v. Krishna Hosp., Inc., 713 S.E.2d 835 (Ga. 2011) (elements of negligence under Georgia law)
Appling v. Jones, 154 S.E.2d 406 (Ga. Ct. App. 1967) ("rage-or-frenzy" exception to suicide intervening cause rule in Georgia)
Goldstein, Garber & Salama, LLC v. J.B., 797 S.E.2d 87 (Ga. 2017) (negligence per se and requirement for proximate cause in Georgia)