This article summarizes and analyzes municipal immunity from liability for torts committed by police officers. Despite the existence of a strong minority, the climate in the United States is not one in favor of the abrogation of the doctrine of governmental immunity in the near future. It should be hoped that in the states where the legislatures have failed to act, the courts will see it as their duty to overturn this anachronism, and that in the states where the courts have refused to part with the past, the legislatures will enact laws to abolish the doctrine. Until such changes in the laws of the majority of the states are enacted, police officers will be held personally liable for their torts, and their employers will not.
Carol F. Dakin, Municipal Immunity in Police Torts, 16 Clev.-Marshall L. Rev. 448 (1967)