Recent case from the Ninth Circuit. The majority held that a police officer violates SDP on a state-created danger theory by disclosing the confidential police report and other information to the abuser. A concurrence in the judgment rejects SCD as a judge-made "Frankenstein's monster" without support in the Fourteenth Amendment, history, or precedent. It is not impossible that the Court reconsiders this doctrine in the not-so-distant future.
The plaintiff lost the case on qualified immunity (which is why the concurrence was not a dissent); we will get to that in a few weeks. Keep this case in your mind and in your notes when we reach that topic; the majority and concurrence analysis illustrate important issues in the doctrine.
Finally, note the particular facts--the abuser communicating with the defendant officer was a fellow officer. This comes up in a fair number of (usually unsuccessful) SCD claims, often around domestic violence--an officer causes harm not under color and the plaintiff argues that the kid gloves with which colleagues treat that officer increase the danger to the victim.
