context: Simpson, 880 So.2d at 1051 (P 14) (holding plaintiff can prove foreseeability by showing "the defendant had actual or constructive knowledge of the assailant's violent nature"). We note California's foreseeability test for spouses of child molesters is actual knowledge.
citation_a.signal: but see
citation_a.identifier: 930 S.W.2d 921, 928
citation_a.parenthetical: holding the test for foreseeability is whether the wife knew or should have known of her husband's proclivities
citation_a.sentence: But see Doe v. Franklin, 930 S.W.2d 921, 928 (Tex.Ct.App.1996) (holding the test for foreseeability is whether the wife knew or should have known of her husband’s proclivities).
citation_b.signal: see also
citation_b.identifier: 714 A.2d 924, 930
citation_b.parenthetical: adopting the "particularized foreseeability" test for spouses of child molesters, "a standard of foreseeability ... that is based on 'particular knowledge' or 'special reason to know'"
citation_b.sentence: Chaney, 46 Cal.Rptr.2d at 76 (quoting Uccello v. Laudenslayer, 44 Cal.App.8d 504, 118 Cal.Rptr. 741, 748 n. 4 (1975)) (“Only where the circumstances are such that the defendant ‘must have known’ and not ‘should have known’ will an inference of actual knowledge be permitted.”); see also J.S. v. R.T.H., 155 N.J. 330, 714 A.2d 924, 930 (1998) (adopting the “particularized foreseeability” test for spouses of child molesters, “a standard of foreseeability ... that is based on ‘particular knowledge’ or ‘special reason to know’”) (citations omitted).