Dora Howell v. City of New York
Dora Howell sued the City of New York and two police officers for negligence after her ex-boyfriend, who had multiple orders of protection against him, brutally attacked and pushed her from a third-floor window. Howell alleged that the defendants failed to provide her with sufficient protection, despite repeated calls about her ex-boyfriend violating the orders. The Court of Appeals affirmed the Appellate Division's decision, concluding that Howell failed to prove the defendants owed her a 'special duty' of care. The majority found no triable issue of fact regarding Howell's justifiable reliance on the police's affirmative undertaking, stating that the mere existence of an order of protection does not, by itself, establish such reliance. Dissenting judges argued that the Domestic Violence Intervention Act (DVIA) established a statutory special duty requiring mandatory arrests for order of protection violations, and that Howell had raised triable issues of fact concerning police control over a dangerous situation and justifiable reliance.