In Laratro v. City of New York (8 NY3d 79, 861 N.E.2d 95, 828 N.Y.S.2d 280 [2006]), the plaintiff sued the City for responding too slowly to a 911 call (the ambulance took 35 minutes to arrive). The court's analysis began with the recognition that "protecting health and safety is one of municipal government's most important duties" (id. at 81) and this responsibility extends to "the duty to provide police protection, fire protection or ambulance service" to the general public (id. at 82-83 ). The court proceeded to determine whether the plaintiff had sufficiently established the existence of a special duty--an inquiry that would have been unnecessary had the court viewed the City's response to the 911 call as a proprietary function. Hence, the court has viewed municipal emergency systems and responses to 911 calls to be within the sphere of governmental functions.