Helen L. Galapo v. City of New…

Summary

The Court affirmed the Appellate Division's dismissal, holding that the New York City Police Department Patrol Guide Procedure 104-1(k) is not a statutory or regulatory requirement that gives rise to liability under General Municipal Law § 205‑e, and that the common‑law “firefighters’ rule” (as applied to police officers in Santangelo) bars the negligence claim. The dissent argued the opposite, contending the Patrol Guide should qualify as a predicate for liability.