Calloway v. Kinkelaar

Plaintiff, Helen Calloway, appeals from an order of the circuit court of Effingham County granting the motions of defendants, Arthur Kinkelaar, as sheriff of Effingham County (hereinafter sheriff), and the county of Effingham (hereinafter county), to dismiss plaintiff’s complaint for failure to state a cause of action. The trial court followed the general rule that law enforcement officials have no duty to protect individual citizens from crime, only a duty to protect the general citizenry. We affirm in part, reverse in part, and remand.

I

Plaintiff brought a four-count complaint against the…