By finding that a special relationship exists between the plaintiff and the police, courts avoid the rule that public duties are not owed to a particular individual. The special relationship exception thereby permits recovering the appropriate case, while generally preserving the public duty doctrine. In 1976, the unanimous State acceptance of the public duty doctrine began to erode. The Alaska Supreme Court rejected the doctrine by characterizing it as another form of sovereign immunity. In Ryan v. State, the Arizona Supreme Court extended the abrogation of the public duty doctrine to cases involving allegations of the State's negligent failure to prevent crime. When the complaint alleges negligent police failure to prevent a crime, courts may reject the public duty doctrine as a defense. State courts should follow the lead of the Attorney General's Task Force on Violent Crime and the Federal courts and apply a gross negligence standard to define the scope of police liability. Abolishing the public duty doctrine would provide opportunities for police officers to vindicate their actions and increase public confidence in the awareness of police work. Any standard that replaces the public duty doctrine must consider the high risks inherent in police work and the current trend of crime victims to seek awards from public entities. A total of 136 footnotes are listed.