In the past, citizens and police officers have considered injury to officers as one of the risks of law enforcement work. Court cases supported this notion with an argument known as the Fireman's Rule. As stated in the Michigan case of Kreski versus Modern Wholesale Electric Supply Co. (1987), "The very nature of police work and fire fighting is to confront danger." Under this view, officers' civil suits against those who cause injury and loss to them are not taken seriously. Although officers are currently more willing to test the courts with civil suits for injuries suffered, the majority of courts still abide by the Fireman's Rule. Still, lawyers are attacking laws that limit officers' ability to sue and using the exceptions that allow it. Aitchison, in his book, "Rights of Law Enforcement Officers," details five categories of officer-as-plaintiff lawsuits. Four of them are discussed in this article: intentional tort, negligence, defamation, and product liability.