Valdez v. City of New York
Carmen Valdez sued the City of New York after her estranged boyfriend shot her, claiming the City failed to provide adequate police protection. Valdez alleged a "special relationship" was formed when Officer Torres promised to "immediately" arrest her boyfriend after a threat, leading her to return home. The jury initially found the City negligent, but the Appellate Division reversed, concluding no special relationship was established due to a lack of justifiable reliance. The Court of Appeals affirmed the Appellate Division's decision, ruling that Valdez's reliance on the officer's promise to arrest her boyfriend "immediately" was not justifiable, especially given the elapsed time and her expectation of a confirmation call. The Court emphasized that a special relationship requires justifiable reliance, which was not met as there were no extraneous factors beyond the promise contributing to her sense of security, and the police did not know the boyfriend's location for an immediate arrest.