Case Note: Chambers-Castanes v. King County

In Chambers-Castanes v. King County, the Washington Supreme Court held that although the public duty doctrine provides that a duty owed to the public as a whole is not an enforceable duty to an individual, a specific duty may arise between the police and an individual where a “special relationship” develops. The court passively noted its continuing support for the public duty doctrine, but found that an exception to the doctrine arises where a “special relationship” develops out of privity between the parties and assurances of protection. The Washington Supreme Court has not expressly discussed the validity of the public duty doctrine but has continually created exceptions to it by finding the existence of some specific duty. This consumption of the doctrine by judicial exception indicates the court’s discomfort with the doctrine and the need for a thorough examination of its utility. In Chambers-Castanes, several calls for assistance were made to the police and assurances were given to the callers that the police had been dispatched, yet the police did not arrive at the scene for approximately one hour and 20 minutes. The incident upon which their claim is based occurred as Steve Ann and Jim Chambers-Castanes were driving through the town of Woodinville, Washington. While stopped in traffic, they were approached by two men who, without warning, began to beat them. Before the police arrived, eleven calls for assistance were made to the police, three by Ms. Chambers-Castanes. Most of the calls were met with assurances that the police had been dispatched. Arriving nearly one hour and 20 minutes later, the police were unable to apprehend the assailants. The transcript of the police tape log indicated that officers had at one point been dispatched but were recalled shortly thereafter.

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Julie A. Lawry, Case Note: Chambers-Castanes v. King County, 19 Gonz. L. Rev. 727 (1984).

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