In Cuffy v. City of New York, 69 N.Y.2d 255, 505 N.E.2d 937, 940, 513 N.Y.S.2d 372 (N.Y. 1987), a case involving a bitter landlord-tenant dispute, the record contained no evidence that one of the plaintiffs, the landlords' son "even knew of the promise of protection. . . ." made by the police after his father requested such protection for his family. 505 N.E.2d at 941. In addition, there was evidence that the mother in Cuffy "had periodically looked out her front window throughout the day of the incident the son was hit with a baseball bat when he sought to visit his parents, and severe injuries also were inflicted on the wife and another son, but had not seen any police pull up in front of her house. . . ." to arrest or restrain the tenant. Id. In light of this evidence, which the court concluded showed no "justifiable reliance," a judgment awarding substantial damages to the plaintiffs was reversed. The Court held that there exists a narrow class of cases in which the court has recognized an exception to the general rule that a municipality may not be held liable for injuries resulting from the failure to provide police protection, and have upheld tort claims based upon a "special relationship" between the municipality and the claimant. The court continued that the elements of this "special relationship" are" (1) an assumption by the municipality, through promises or actions, of an affirmative duty to act on behalf of the party who was injured; (2) knowledge on the part of the municipality's agents that inaction could lead to harm; (3) some form of direct contact between the municipality's agents and the injured party; and (4) that party's justifiable reliance on the municipality's affirmative undertaking. The court also stated that the injured party's reliance is as critical in establishing the existence of "special relationship" as is the municipality's voluntary affirmative undertaking of a duty to act. That element provides the essential causative link between the "special duty" assumed by the municipality and the alleged injury. The court recognized that an exception to the general rule can be found in a narrow class of cases where there exists a "special relationship" between the municipality and the claimant. The elements of the "special relationship" or "special duty" exception are: (1) an assumption by the municipality, through promises or actions, of an affirmative duty to act on behalf of the party who was injured; (2) knowledge on the part of the municipality's agents that inaction could lead to harm; (3) some form of direct contact between the municipality's agents and the injured party; (4) the party's justifiable reliance on the municipality's affirmative undertaking (Id. at p. 260.)