In NeCasek v. City of Los Angeles (1965) 233 Cal.App.2d 131, the court considered whether police officers would be held liable for injury caused by escaping arrestees who fled on foot and knocked a woman down. At the time section 845.8 only immunized from liability for injuries caused by an escaped prisoner. Therefore, the court looked to public policy considerations to determine whether the officers' failure to sufficiently physically restrain the arrestees was an immune discretionary act. The court concluded that to impose such liability would be to encourage too much force in order to forestall such claims. "A rule of law which may encourage police brutality is not desirable." ( Id., at p. 137.)