Drawing upon the general principle that a State actor may violate section 1983 by failing to lend aid to a person in need, courts have begun to recognize that police must assist battered women and must be held liable for their failure to do so if certain conditions are present. Some courts have used equal protection analysis to impose liability upon police officers who fail to act to protect citizens. The 1989 U.S. Supreme Court case of DeShaney v. Winnebago County Department of Social Services, however, substantially narrowed the circumstances under which a special relationship between a victim and a police officer may arise, thus forcing lower courts to rely on alternate legal doctrines to aid battered women. The best solution to such legal uncertainty is for State legislatures to draft statutes that require police officers to provide affirmative protection to victims of domestic violence and to make arrests when arriving at the scene of the violence. Such a statutorily defined duty provides clarity for both police officers and domestic violence victims regarding the extent of the police officer's required action. 224 footnotes