In New York State a municipality cannot be held liable for injuries resulting from a failure to provide police protection unless a special relationship exists between the municipality and the injured party. This rule is based on the principle, as stated by the Court of Appeals in Cuffy v. City of New York, that “a municipality’s duty to provide police protection is ordinarily one owed to the public at large and not to any particular individual or class of individuals.”1

Although it seems reasonable that those employed to protect us from harm will do so, in reality this cannot always be accomplished. For example, the New York City Police Department is comprised of approximately 34,500 officers2 and is responsible for the protection and safety of more than eight million inhabitants.3 It would be impossible to protect all.

A Special Relationship

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