The lawsuits involving assault have often been successful, although recovery in defamation cases is difficult if the plaintiff is a public figure. In some cases the filing of direct claims against individuals lead to counterclaims, which are sometimes successful. A major barrier to recovery by public safety is the "fireman's rule" adopted by the majority of States. This rule states that these personnel cannot normally recover for negligence leading to injury to them when they are confronting the normal and foreseeable risks of their profession. Other barriers to recovery may relate to workers' compensation issues. Descriptions of judicial decisions in sample cases.