95 N.Y.2d 568 (2000)

A police department’s internal rules and procedures, such as those found in a patrol guide, do not constitute a “well-developed body of law” imposing clear legal duties and therefore cannot serve as the basis for civil liability under General Municipal Law § 205-e.

Summary

This case addresses whether a violation of the New York City Police Department Patrol Guide can serve as the basis for liability under General Municipal Law § 205-e, which allows police officers to recover damages for injuries caused by the violation of governmental requirements. The Court of Appeals held that the Patrol Guide, as an internal manual, does not establish clear legal duties sufficient to ground liability under the statute. This decision limits the scope of § 205-e, preventing its use for breaches of internal policies not codified in law, thus protecting municipalities from excessive liability and preserving departmental autonomy in setting internal guidelines.

Facts

Sergeant Martin, participating in a