In Santangelo v. State of New York, 71 N.Y.2d 393 (1988), the Court of Appeals stated that "like firefighters, police are the experts engaged, trained and compensated by the public to deal on its behalf with emergencies and hazards often created by negligence, and like firefighters, they generally cannot recover damages for negligence in the very situations that create the occasion for their services." Therefore, the "firefighter's rule" also applies to police officers. It is known as the Santangelo rule. The Court of Appeals extended the applicability of the then well settled common law rule that firefighters injured while fighting fires could not "recover against the property owners or occupants whose negligence in maintaining the premises occasioned the fires" (id. at 396), to police officers who were injured while performing their duties (id. at 395). Specifically, the court held that "like firefighters, police are the experts engaged, trained and compensated by the public to deal on its behalf with emergencies and hazards often created by negligence" (id. at 397), and, thus, generally cannot recover damages for negligence in the very situations that create the occasion for their services (id.). The court again noted the bar on common law negligence claims so as to preclude an action against the state, who in Santangelo, employed the plaintiff (id. at 395, 398.)