To establish that a person has "taken charge" of another, that person must " ‘through affirmative action assum[e] an obligation or intend[ ] to render services for the benefit of another.’ " ( Carson , supra , 326 S.C. at p. 218, 486 S.E.2d 3.) Typically, a person takes charge of another person by taking physical custody of him ( Wakulich v. Mraz (Ill. 2003) 203 Ill. 2d 223, 226-227, 245, 271 Ill.Dec. 649, 785 N.E.2d 843 [defendants gave plaintiff dangerous alcoholic beverage and decided to care for her when she passed out]; Sung-Ho Hwang v. Grace Rd. Church (E.D.N.Y. 2016) 2016 WL 1060247, *13, 2016 U.S. Dist. LEXIS 32824, *38-*39 [defendant restrained plaintiff on its property and did not seek medical care for his gangrene ] ) or by taking "responsibility for [his] overall safety" ( Hinson v. Black (Ga. App. 2002) 257 Ga. App. 628, 631-632, 572 S.E.2d 653 ( Hinson ); e.g., Downs ex rel. Downs v. Bush (Tenn. 2008) 263 S.W.3d 812, 823 [defendant agreed to give incapacitated plaintiff a ride home and helped him get into bed of truck]; Sarracino v. Martinez (N.M. Ct. App. 1994) 117 N.M. 193, 194-195, 870 P.2d 155 [same]; David v. Southern Farm Bureau Casualty Ins. Co. (La. Ct. App. 1960) 122 So.2d 691, 692 [defendant agreed to take plaintiff to nearest hospital]; Ocotillo , supra , 173 Ariz. at pp. 487-490, 844 P.2d 653 [defendant took plaintiff’s car keys because plaintiff was intoxicated, but then gave keys back to plaintiff]; Shizuko Mita v. Guardsmark, LLC (Wash. Ct. App. 2014) 182 Wash. App. 76, 88-89, 328 P.3d 962 [defendant allowed plaintiff to come into building out of the freezing cold, then released him back outside] ). However, a person does not "take charge" of another merely by making suggestions or giving "cursory assistance" short of assuming responsibility for his safety.