The police owe a duty of care in employing deadly force.  However, that duty applies only where it is the police’s use of force that kills or injures the plaintiff, not where, as in this case, the police’s use of force triggers another person to engage in violence that kills or injures the plaintiff.  Here, the police fired at an armed man who had taken hostages.  The police missed him and didn’t hit any of the hostages.  After the police stopped shooting, the armed man shot his hostages and himself.  In that situation, the police duty to use care in employing deadline force doesn’t apply.  The police also could not be held liable on the theory that their conduct increased the risk of harm to the hostages, that they had undertaken any duty to protect the hostages against the gunman’s acts, or that they had a special relationship with the hostages.