Warren v. District of Columbia “is a District of Columbia Court of Appeals case that held that the police do not owe a specific duty to provide police services to specific citizens based on the public duty doctrine.” And Castle Rock v. Gonzales, is a United States Supreme Court case in which the Court ruled, 7–2, that a town and its police department could not be sued under 42 U.S.C. § 1983 for refusing to enforce a restraining order, even though the refusal led to the murders of a woman’s three children by her estranged husband.