In 1989, the Supreme Court found in DeShaney v. Winnebago County Department of Social Services that State officials have no obligation to protect private citizens from violence or injury caused by other private citizens. DeShaney v. Winnebago Cnty. Dept. of Soc. Services, 489 U.S. 189, 194 (1989) (finding county authorities not liable when a child in its custody was seriously injured by his father). Writing for the Court, Chief Justice Rehnquist explained the Due Process Clause limits a state’s power to deprive individuals of “life, liberty, and property without due process,” but does not create an affirmative duty to protect individuals. Id. at 194, (quoting U.S. Const. amend. XIV, § 1). Thus, state actors cannot be held liable for harm caused to private citizens under 42 U.S.C. § 1983. However, in DeShaney, the Court identified two possible exceptions in which a private citizen may be entitled to protection. The first, known as the Special Relationship Exception, is often applied when a state incarcerates, institutionalizes, or restrains a person involuntarily. DeShaney, 489 U.S. at 198-99; see Christopher M. Eisenhauer, Police Action and the State-Created Danger Doctrine: a Proposed Uniform Test, 120 DICK. L. REV. 893 (2016).