In Crosland v. New York City Transit Authority (68 N.Y.2d 165 [1986]), the Court of Appeals held that governmental immunity should not protect municipal employees who fail to intervene to protect citizens from criminal assault. In Crosland, the complaint alleged that a transit authority employee witnessed a brutal assault committed on the plaintiff from a protected booth, but inexplicably failed to summon aid, although he could have done so without risk to himself.