Courts have never supported claims of failure to protect just because a crime was committed and the victim was injured. Thus, law enforcement officers owe no duty to specific individuals injured by crime unless a special relationship has been created between the crime victim and the law enforcement authorities. Courts have found such special relationships to exist in cases of failure to respond to calls for assistance, failure to arrest or restrain persons who are committing or are about to commit violent crimes, and cases where a duty to protect has been or appears to have been assumed and has been relied upon by the victim. Other situations include the failure to protect persons whom the authorities have brought into contact with the assailants or those who have helped law enforcement officers. The judicial decisions on the subject show that law enforcement agencies should recognize that a duty to protect has been established when officers have reason to know that specific individuals are in a position of foreseeable danger, when implying a promise of protection through the publication of emergency numbers, when specific promises of protection are made, and when the police put individuals in a position of danger. 15 footnotes.