In Warren v. District of Columbia (1981), the D.C. Court of Appeals ruled, “official police personnel and the government employing them are not generally liable to victims of criminal acts for failure to provide adequate police protection . . . a government and its agents are under no general duty to provide public services, such as police protection, to any particular citizen.” In Bowers v. DeVito (1982), the Seventh Circuit Court of Appeals ruled, “[T]here is no constitutional right to be protected by the state against being murdered by criminals or madmen.”
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