The "special duty" rule is perhaps one of the thorniest and most confusing areas of tort law. It requires that a municipality, when performing a governmental function, be found to have owed a duty to the injured party greater than whatever obligation it may have had to the public at large in order to be held liable. For example, a person cannot sue a police department purely for failing to protect him from harm by a third party. But, if the police make a specific promise to protect a person, who relies on that promise to his detriment, and they then fail to deliver on it, the municipality may be found to have accepted a special duty and be held liable. See, e.g., Cuffy v. City of New York, 69 N.Y.2d 255 (1987).