Weiner v. Metropolitan Transportation Authority, 55 N.Y.2d 175 (1982)
A municipality’s duty to provide police protection is typically owed to the public at large, but a special duty of care may arise when the municipality undertakes affirmative action that creates a justifiable reliance on the part of a specific individual or a defined class of individuals.
Summary
In this case, the New York Court of Appeals considered whether the City of New York owed a special duty of care to a plaintiff shot by a sniper during a period of public crisis. The plaintiff argued that the city, by directing him into the line of fire, assumed a special duty to protect him. The Court of Appeals held that, under the circumstances, no special duty was created. The decision emphasizes that while municipalities generally owe a duty to the public at large, a special duty to an individual can arise from specific actions or representations creating justifiable reliance. The dissent argued for further factual exploration, particularly regarding the city’s actions and the plaintiff’s reliance.
Facts
During a period of sniper attacks on elevated trains in New York City, the plaintiff was shot and injured. The plaintiff claimed that an agent of the city directed him into the line of fire, thereby creating a special duty of care. The plaintiff asserted that the city’s actions went beyond general police protection and constituted a specific undertaking to protect him from the sniper.
Procedural History
The Special Term denied the defendant’s motion for summary judgment. The Appellate Division reversed the Special Term’s order. The Court of Appeals affirmed the Appellate Division’s order, dismissing the plaintiff’s claim.
Issue(s)
Whether the City of New York, by directing the plaintiff into a dangerous situation during a sniper attack, assumed a special duty of care to protect him from the sniper’s gunfire, thereby rendering the city liable for his injuries.
Holding
No, because the city’s actions did not create a special relationship with the plaintiff that would give rise to a specific duty of care beyond the general duty owed to the public. The plaintiff failed to demonstrate justifiable reliance on any affirmative promise or action by the city.
Court’s Reasoning
The court reasoned that the city’s general duty to provide police protection extends to the public at large, and not to specific individuals, unless a special relationship exists. To establish a special relationship, the plaintiff must demonstrate that the municipality undertook affirmative action that created a justifiable reliance on the part of the plaintiff. The court found that the plaintiff’s allegations did not establish such reliance. The court distinguished this case from situations where the municipality made direct promises or assurances to the plaintiff. The court emphasized that imposing liability in this context would create an undue burden on municipalities in crisis situations. The court stated that “[i]t is well settled that a municipality’s duty to provide police protection is owed to the public at large and not to any particular individual or class of individuals” unless a special relationship exists.