Supreme Court of the State of Washington



                            Opinion Information Sheet



Docket Number:       76249-0

Title of Case:       Mary A. Cummins, Petitioner,  v. Lewis County,

                     et al., Respondents.

File Date:           05/04/2006

Oral Argument Date:  09/13/2005





                                SOURCE OF APPEAL

                                ----------------

Appeal from Superior Court,

            Lewis County

            00-2-01542-7

            Honorable Richard Lynn Brosey





                                    JUSTICES

                                    --------

Authored by Gerry L Alexander

Concurring: James Johnson

            Barbara A. Madsen

            Bobbe J Bridge

            Charles W. Johnson

            Richard B. Sanders

            Susan Owens

            Tom Chambers

            Mary Fairhurst





                                COUNSEL OF RECORD

                                -----------------

Counsel for Petitioner(s)

            Howard Mark Goodfriend

            Edwards Sieh Smith & Goodfriend PS

            1109 1st Ave Ste 500

            Seattle, WA  98101-2988



            Terry E. Lumsden

            Law Offices of Terry E Lumsden

            3517 6th Ave Ste 200

            Tacoma, WA  98406-5403



            Devin T Theriot-Orr

            Edwards Sieh Smith & Goodfriend PS

            1109 1st Ave Ste 500

            Seattle, WA  98101-2988



Counsel for Respondent(s)

            Robert William Novasky

            Burgess Fitzer PS

            1145 Broadway Ste 400

            Tacoma, WA  98402-3584



            Melanie T Stella

            Burgess Fitzer PS

            1145 Broadway Ste 400

            Tacoma, WA  98402-3584



Amicus Curiae on behalf of WASHINGTON STATE TRIAL LAWYERS ASSOC FOUNDATION

            Bryan Patrick Harnetiaux

            Attorney at Law

            517 E 17th Ave

            Spokane, WA  99203-2210



            Debra Leigh Williams Stephens

            Attorney at Law

            6210 E Lincoln Ln

            Spokane, WA  99217-9332





IN THE SUPREME COURT OF THE STATE OF WASHINGTON



MARY A. CUMMINS, individually, and as            )

Personal Representative of the Estate of         ) No. 76249-0

LEON V. CUMMINS, deceased,                       )

                                                 )

               Petitioner,                       )

                                                 )

     v.                                          ) En Banc

                                                 )

LEWIS COUNTY, a municipality,                    )

                                                 )

               Respondent,                       )

                                                 )

CITY OF CENTRALIA, a municipality; QWEST         )

CORPORATION, formerly doing business as          )

US WEST COMMUNICATIONS, a foreign                )

corporation; NORTHERN TELECOM                    )

MERIDIAN SYSTEMS, INC., a Washington             )

corporation; NORTHERN TELECOM                    )

INTERNATIONAL, INC., a Washington                )

corporation; PLANT EQUIPMENT, INC., a            )

foreign corporation; INFORMER COMPUTER           )

SYSTEMS, INC., a foreign corporation; SCC        )

COMMUNICATIONS CORP., a foreign                  )

corporation; CHRISTOPHER BIRD, a minor;          )

S. PAULA BIRD, and "JOHN DOE" BIRD,              )

husband and wife, individually and their marital )

community; and JOHN DOES 1-5,                    )

                                                 )

               Defendants.                       )

                                                 ) Filed May 4, 2006



ALEXANDER, C.J.--The question presented in this case is whether, under the

public duty doctrine, an actionable "special relationship" is created

between a member of the public and a government entity when an individual

places a "911 call," identifies the nature of his medical emergency,

provides a street address but not his name, and "hangs up" prior to either

requesting help or receiving an oral assurance from the operator that

medical aid will be dispatched.  We answer "no" to that question,

concluding that there is neither a statutory nor a common law duty on the

part of a county to dispatch medical aid under such circumstances.  We

decline also the petitioner's invitation to eliminate the express assurance

requirement of the special relationship inquiry in cases involving 911

calls and medical emergencies.  We, therefore, affirm the Court of Appeals'

decision upholding the Lewis County Superior Court's summary judgment

dismissing the petitioner's wrongful death action.

I. FACTS

On December 15, 1997, the Lewis County emergency dispatch call center

received a 911 call.  The 911 dispatcher heard what she believed to be the

voice of an adult male say, "1018 'E' Street, heart attack."  Clerk's

Papers at 343.  The caller hung up the telephone before the dispatcher

could obtain additional information and before she could respond.

On the date of this incident, Lewis County had in place an "enhanced 911

(E911) system{}."  Id. at 303.  Unlike a regular 911 service, the E911

system automatically displays the telephone number and location from which

a call is placed.  In this instance, the system indicated that the "'heart

attack call'" was placed from a pay telephone in the vicinity of a grocery

store on Tower Street in Centralia.  Id. at 376.  That location is roughly

five blocks from the "E" Street address furnished by the caller.  A few

minutes before the call in question, the 911 dispatcher had fielded a so-

called "prank" 911 call from the same Tower Street pay telephone.  Id.

Immediately after receiving the "heart attack" call, the dispatcher dialed

the pay telephone number and received a busy signal.  Another operator

placed a telephone call to the "E" Street address and received a recorded

answer from an answering machine.  This caused the dispatcher to treat the

"heart attack" call as a "hang up," meaning she did not immediately send

medical aid to either location.  Id. at 338.  Instead, she dispatched a

Centralia police officer to conduct an investigation.

In response to the directions from the dispatcher, a Centralia police

officer drove to the location of the pay telephone.  Upon arriving there,

he stopped a young man who was in the vicinity.  The boy was well-known to

the Centralia Police Department due to his prior contacts with that

department.  When questioned, the youngster said that he had placed the 911

call.  The officer then issued a warning to the boy and cleared the call

with 911 as a "suspicious circumstance."  Id. at 369.  The dispatcher

indicated to the officer that she was surprised that a boy made the "heart

attack" call given that it was a man's voice that she had heard.  The

officer responded that the boy tried to make his voice sound "old."  Id. at

349.  After clearing the call, the police officer proceeded to the "E"

Street address.  He did not, however, stop at that location or attempt to

contact anyone who may have been at the home.

Several hours later, Mary A. Cummins, the plaintiff and petitioner here,

returned home to the "E" Street address and found her husband, Leon V.

Cummins, dead on the kitchen floor.  Mrs. Cummins called 911.  The E911

system identified her call as coming from 1018 "E" Street.  This prompted

the police officer who had earlier contacted the young man in the vicinity

of the pay telephone to recontact him.  The youth told the officer that he

had lied about making the earlier call.  The E911 system was thereafter

checked and found to be functioning properly.

Mrs. Cummins brought a wrongful death action in Lewis County Superior Court

against Lewis County and the City of Centralia in her own capacity as well

as in a representative capacity.  She alleged that her husband's death was

the result of the negligence of the Lewis County 911 emergency dispatch

unit as well as that of the Centralia police department which had responded

to the call.  The trial court granted a summary judgment dismissing Mrs.

Cummins's complaint against both defendants.  The court held that she

failed to show that the county or the city owed Mr. Cummins a duty of care

it did not owe to the public generally and that her claims were thereby

barred by the public duty doctrine.  Division Two of the Court of Appeals

affirmed the superior court.1  Mrs. Cummins sought and was granted review

by this court. 2

II. LEWIS COUNTY'S MOTION TO STRIKE

     During our consideration of this case, respondent Lewis County moved

to strike a supplemental brief that Mrs. Cummins filed in response to an

amicus curiae brief submitted by the Washington State Trial Lawyers

Association Foundation (Foundation).3  The Foundation asked in its brief

that this court permanently "inter" the public duty doctrine.4  In her

response, Mrs. Cummins adopted for the first time this line of reasoning

and joined the Foundation in requesting that this court abandon the public

duty doctrine.  Mrs. Cummins argued additionally, and for the first time,

that the special relationship exception to the doctrine should henceforth

be limited to analyzing a government's duty only in those cases involving

the criminal acts of third parties.

Lewis County correctly notes that Mrs. Cummins initially sought this

court's review only on the questions of whether a special relationship with

the county had been established and whether the express assurance

requirement needed to establish that particular relationship be eliminated

or relaxed for medical emergency callers.  It is a well-established maxim

that this court will generally not address arguments raised for the first

time in a supplemental brief and not made originally by the petitioner or

respondent within the petition for review or the response to petition.  See

Douglas v. Freeman, 117 Wn.2d 242, 258, 814 P.2d 1160 (1991).  Because Mrs.

Cummins seeks a form of relief in her supplemental brief that she did not

seek in her petition for review, Lewis County's motion to strike is

granted.

III.  THE PUBLIC DUTY DOCTRINE AND THE SPECIAL RELATIONSHIP

EXCEPTION THERETO



Mrs. Cummins contends that the trial court and Court of Appeals each erred

in not concluding that an actionable special relationship was created

between Lewis County and Leon Cummins when Mr. Cummins telephoned 911 and

stated both his physical location and the nature of his medical emergency.5

Pointing to a long line of Washington public duty doctrine cases, Lewis

County asserts that both courts below correctly determined that Mrs.

Cummins does not have an actionable claim in negligence because the 911

dispatcher who fielded Mr. Cummins's call did not give him an "express

assurance" of help upon which he could have "justifiably relie{d}."  Resp't

Lewis County's Suppl. Br. at 7.

When reviewing an order on summary judgment, this court engages in the same

inquiry as the trial court.  Babcock v. Mason County Fire Dist. No. 6, 144

Wn.2d 774, 784, 30 P.3d 1261 (2001).  Summary judgment is proper where the

entire record demonstrates there is no genuine issue of material fact and

the moving party is entitled to judgment as a matter of law.  In a

negligence action, the determination of whether an actionable duty was owed

to the plaintiff represents a question of law to be decided by the court.

Tincani v. Inland Empire Zoological Soc'y, 124 Wn.2d 121, 128, 875 P.2d 621

(1994).  A question of law is reviewed do novo.  Babcock, 144 Wn.2d at 784.

A threshold negligence determination is whether a duty of care is owed to

the plaintiff.  Id. at 784-85 (quoting Taylor v. Stevens County, 111 Wn.2d

159, 163, 759 P.2d 447 (1998)).  In negligence actions against a government

entity, Washington courts follow the rule that

to be actionable, the duty must be one owed to the injured plaintiff, and

not one owed to the public in general.  This basic principle of negligence

law is expressed in the "public duty doctrine".  Under the public duty

doctrine, no liability may be imposed for a public official's negligent

conduct unless it is shown that "the duty breached was owed to the injured

person as an individual and was not merely the breach of an obligation owed

to the public in general (i.e., a duty to all is a duty to no one)."



Taylor, 111 Wn.2d at 163 (citations omitted) (quoting J & B Dev. Co. v.

King County, 100 Wn.2d 299, 303, 669 P.2d 468 (1983)).

The public duty doctrine does not serve to bar a suit in negligence against

a government entity.  As a result of the enactment in 1967 of RCW 4.96.010,

which did away with Washington's shield of absolute sovereign immunity,

local governments such as a county may be liable for damages arising out of

their tortious conduct, or the tortious conduct of its employees "to the

same extent as if they were a private person or corporation."  RCW

4.96.010(1); Bailey v. Town of Forks, 108 Wn.2d 262, 265, 737 P.2d 1257,

753 P.2d 523 (1987).  In this light, the doctrine serves as a framework for

courts to use when determining when a governmental entity owes either a

statutory or common law duty to a plaintiff suing in negligence.  See,

e.g., Jenifer Kay Marcus, Washington's Special Relationship Exception to

the Public Duty Doctrine, 64 Wash. L. Rev. 401, 401 (1989).6

There are four common law "exceptions" to the public duty doctrine.7  If

one of these exceptions applies, the government will be held as a matter of

law to owe a duty to the individual plaintiff or to a limited class of

plaintiffs.  Bailey, 108 Wn.2d at 268.  At issue in this case is

application of the special relationship exception.

A.   Has Mrs. Cummins satisfied the three requirements of the special

relationship exception?



The special relationship exception allows tort actions for negligent

performance of public duties if the plaintiff can prove circumstances

setting his or her relationship with the government apart from that of the

general public.  Taylor, 111 Wn.2d at 166.  A special relationship imposing

an actionable duty to perform arises between the plaintiff and a government

entity when "'(1) there is a direct contact or privity between the public

official and the injured plaintiff which sets the latter apart from the

general public, and (2) there are express assurances given by a public

official, which (3) gives rise to justifiable reliance on the part of the

plaintiff.'"  Beal v. City of Seattle, 134 Wn.2d 769, 785, 954 P.2d 237

(1998) (quoting Taylor, 111 Wn.2d at 166).

1. Was there privity between Mr. Cummins and Lewis County?

Mrs. Cummins asserts that privity was established at the point when Mr.

Cummins telephoned 911 and was able to state both his physical location and

the nature of his medical emergency to an operator.  Lewis County contends

that Division Two of the Court of Appeals correctly held that in order for

privity to exist in this context some form of communication between the 911

caller and the operator must occur.  See Cummins v. Lewis County, 124 Wn.

App. 247, 254, 98 P.3d 822 (2004).

Mrs. Cummins correctly observes that a plaintiff can establish privity

without having to prove the plaintiff herself communicated with the

government entity.  See Bratton v. Welp, 145 Wn.2d 572, 577, 39 P.3d 959

(2002).  She is not correct, however, that prior case law establishes that

the privity element is satisfied merely by the act of placing a call to

911.  Washington case law shows the required communication between the

injured party and 911 by which the plaintiff is set apart from the general

public requires both a (1) telephone conversation and (2) an affirmative

promise or agreement to provide assistance.  Accord id.; Beal, 134 Wn.2d at

785; Chambers-Castanes v. King County, 100 Wn.2d 275, 286, 669 P.2d 451

(1983).

In each of the above cases, the plaintiff established privity by showing

that the 911 dispatcher affirmatively communicated some form of "promise"

that assistance would be sent.  Furthermore, in each of these cases, the

911 caller established a dialogue with the government official after

identifying the nature of his emergency and communicating his identity to

the government official, thereby separating himself from the public at

large.  None of these activities have been shown here, the record revealing

that Mr. Cummins hung up the telephone before a promise of assistance could

be given and before an on-going dialogue could be established.

Furthermore, he did not identify himself.  This one-way communication was

not sufficient to establish privity in the 911 context.

2. Was an express assurance given?

Mrs. Cummins must also show Mr. Cummins received an express assurance from

a government official.  Mr. Cummins must have sought an express assurance

of assistance, and the government must have unequivocally given that

assurance.  Babcock, 144 Wn.2d at 789.  "A government duty cannot arise

from implied assurances."  Id. (citing Honcoop v. State, 111 Wn.2d 182, 192-

93, 759 P.2d 1188 (1988); Taylor, 111 Wn.2d at 167).

Mrs. Cummins does not contend that the 911 operator unequivocally gave Mr.

Cummins an express promise that medical assistance would be dispatched.

Under Washington case law, this absence of an express assurance to dispatch

assistance by the operator precludes this court from finding as a matter of

law that Mrs. Cummins has established an actionable duty against the

county.  Accord Babcock, 144 Wn.2d at 791.

     To meet the express assurance requirement, Mrs. Cummins argues more

generally that the nature of the E911 system provides an "inherent"

government assurance that medical assistance will be forthcoming once a

call is placed.  This argument fails.  Even if this court were to decide

that the very nature of the 911 system provides the public with an

"inherent" promise of emergency aid dispatch, Mrs. Cummins cites no

authority for equating an "inherent" assurance to the required express

assurance.  Thus, we conclude that an inherent assurance, like an implied

assurance, does not provide us with a sufficient basis for finding an

actionable duty under the special relationship exception.  See Meaney v.

Dodd, 111 Wn.2d 174, 180, 759 P.2d 455 (1988); Taylor, 111 Wn.2d at 168

(overruling in part J & B Dev. Co., 100 Wn.2d 299 (1983), a case imposing

government liability in part on the government's implicit assurances that

the plaintiff had complied with building codes).  Because Mrs. Cummins

fails to show the 911 operator gave Mr. Cummins an unequivocal statement

that assistance would be forthcoming, we conclude as a matter of law that

no express assurance was provided.

3. Was there justifiable reliance on the part of Mr. Cummins?

     Mrs. Cummins must further demonstrate sufficient facts showing that

Mr. Cummins justifiably relied on an explicit assurance given by the 911

operator.  Babcock, 144 Wn.2d at 791-92.  To bind the government, Mr.

Cummins must have relied upon the assurance to his detriment.  Id. at 793.

Even after viewing the facts and inferences in a light most favorable to

her, we are satisfied that Mrs. Cummins has not shown that Mr. Cummins

justifiably relied upon an explicit promise of assistance or that he relied

on an assurance to his detriment.  First, as noted above, the 911 operator

did not communicate an express assurance of assistance upon which Mr.

Cummins could have relied.  Second, even if this court were to infer that

Mr. Cummins was provided an assistance promise, Mrs. Cummins does not show

Mr. Cummins was induced to and did purposefully remain at his physical

location awaiting help in reliance upon the dispatcher's assistance

assurance.  Accord Beal, 134 Wn.2d at 786 (justifiable reliance found when

911 operator gave assurance that police protection was on the way and

shooting victim consciously waited for officers to arrive at the location

based upon that assurance); Noakes v. City of Seattle, 77 Wn. App. 694,

700, 895 P.2d 842 (1995) (reliance found where plaintiffs remained in the

house in anticipation of police assistance rather than attempting to escape

or to use self-help in removing an intruder).  Rather, under the facts

submitted, it is likely that given the severity of the heart attack Mr.

Cummins was physically unable to move beyond his home and, thus, he was not

induced to remain there and/or did not eschew other avenues of help as a

result of the 911 call.

Mrs. Cummins seeks to satisfy the reliance requirement by generally

asserting that "{a} caller seeking assistance for a medical emergency does

so in reliance on the government's promise {under RCW 38.52.500} to provide

a rapid response."  Pet. for Review at 12.  However, this court cannot as a

matter of law use a broad statement of legislative intent as the sole basis

from which to find factually that a 911 caller justifiably relied upon a

911 operator's alleged promise of aid.  Mrs. Cummins fails to show the

necessary reliance.

B.   Should we accede to Mrs. Cummins's novel request to relax or eliminate

the

express assurance requirement in 911 cases where medical aid is sought?



In the face of case law demonstrating she has not satisfied the three

elements necessary to establish a "special relationship," Mrs. Cummins asks

this court to modify the test for emergency medical condition 911 callers.

The rule of law Mrs. Cummins proposes would strike out the "express

assurance" element from the "special relationship" determination in 911

medical emergency cases only.  Mrs. Cummins does not, however, propose to

eliminate application of this requirement for determining a government

entity's duty to respond to 911 calls for either police or fire

emergencies.

Mrs. Cummins supports her position by arguing that a municipality's duty to

provide emergency medical services is different, and thus distinguishable,

from its duty to provide emergency police or fire services.  She argues

that medical aid focuses on a single individual, whereas the duty to

prevent crime is owed to the public at large.  "Unlike police protection .

. .," she writes, dispatching ambulance services is "not a traditional

governmental function provided to the public at large.  Instead, government

has taken over the role of emergency response and transport formerly

performed by private ambulance services.  This duty is owed not to the

public at large but only to specific individuals requesting assistance."

Pet. for Review at 17.

In response, Lewis County asserts that there is no justification as a

matter of law for treating 911 callers differently based on the nature of

the caller's emergency.  The county notes that the public is encouraged to

call 911 in the case of any type of emergency.  The county asks us to

reject Mrs. Cummins's proposal, arguing that a county's duty to provide 911

services to the public cannot be greater or lesser depending on whether a

call is for medical or police aid because it has a statutory obligation to

field both kinds of calls.  We agree with the county.

Mrs. Cummins cites no case law from Washington or from other jurisdictions

to support her proposition that a governmental unit's duty to respond to a

911 medical emergency caller is somehow greater than that owed to a caller

who phones with another type of 911 emergency.  As previously defined by

this court, a municipality's duty to respond to a 911 call is a general

duty owed to all regardless of the type of aid requested.

The District of Columbia Court of Appeals has rejected an argument similar

to that advanced by Mrs. Cummins.  In Hines v. District of Columbia, 580

A.2d 133, 135-36 (D.C. App. 1990), the decedent's personal representative

sued the District for wrongful death damages arising from the alleged

negligent dispatch of medical emergency services.  The personal

representative's claim in that case, similar to that which Mrs. Cummins

makes here, was analyzed within the parameters of the public duty doctrine

and was dismissed by the trial court on summary judgment.  Unlike this

case, there was an express promise in Hines by the dispatcher to render aid

and emergency aid was actually sent--though it was alleged by the plaintiff

that the life support unit was not dispatched in a timely fashion.

Seeking to get around the public duty doctrine in the District of Columbia

case, the personal representative argued on appeal that the doctrine should

not apply to calls for emergency medical services.  Like the instant case,

the personal representative sought to distinguish the duty to dispatch

ambulance services from police and fire protection on the basis that

emergency medical attention is summoned for and focuses on a particular

individual, whereas the duty to prevent crime and protect against fires is

owed to the public at large.  In rejecting the personal representative's

invitation to make such a distinction and to find that an exempted special

relationship forms at the exact point in time emergency medical services

have been requested, the District of Columbia court wrote:

Virtually every citizen of the District {of Columbia} could find himself or

herself in need of assistance from the EAD {Emergency Ambulance Division}

at one time or another; if there is a particular "class" of citizens who

benefit, its members are distinguished from the general public only in that

they are temporarily in need of emergency services.  In this, they do not

differ from citizens who find themselves in need of emergency police or

fire services.



Id. at 138.



The District of Columbia Court of Appeals continued its reasoning by noting

that every member of the public may become a "temporary member{} of one or

more of these 'classes' {of persons in need of emergency fire, police, or

medical aid} at some time."  Id.  The court indicated that by virtue of

being an individual who calls for emergency medical assistance, the person

does not put himself or herself in a class in a "sense that would justify

invoking the special relationship exception to the public duty doctrine."

Id.  In our view, the District of Columbia court's reasoning is logical,

and we adopt its reasoning as a basis for rejecting Mrs. Cummins's request

to create an exception to the public duty doctrine for medical emergency

calls or to impose a heightened duty to respond to only this type of call.

Like the District of Columbia case law, jurisprudence from this state does

not define the duty owed by a government entity to respond to a member of

the public based upon the underlying nature of the individual's problem.

Rather, Washington courts have applied the public duty doctrine uniformly

in a variety of governmental negligence claims,8 and where duty is analyzed

based upon the assertion of a special relationship exception, the courts

look to the manner and extent of contact between the government official

and the member of the public and also look to how explicit were the

assurances of aid allegedly created thereby.  Mrs. Cummins provides neither

a strong public policy nor a sound legal argument for moving away from this

line of analysis.

IV. CONCLUSION

In sum, we conclude that Mrs. Cummins has failed to produce facts which

show that she satisfies any one of the three requirements of an actionable

special relationship.  The record demonstrates that the county was merely

carrying out responsibilities it generally owed to the public when it

fielded Mr. Cummins's call and that no common law duty was owed to Mr.

Cummins individually or as a member of a particular class under these

circumstances.  Additionally, we decline Mrs. Cummins's invitation to

depart from existing Washington precedent by eliminating the express

assurance requirement of the special relationship test in only those cases

involving 911 calls and medical emergencies.  The Court of Appeals is,

therefore, affirmed.



AUTHOR:

     Chief Justice Gerry L.

     Alexander



WE CONCUR:



                                           Justice Susan Owens

     Justice Barbara A. Madsen             Justice Mary E. Fairhurst

                                           Justice James M. Johnson

     Justice Bobbe J. Bridge



1Cummins v. Lewis County, 124 Wn. App. 247, 257, 98 P.3d 822 (2004).

2By joint motion, the City of Centralia was dismissed as a party to this

review.  Thus, Mrs. Cummins sought and was granted review of the Court of

Appeals' decision only as it applies to respondent Lewis County.  Cummins

v. Lewis County, 154 Wn.2d 1030 (2005).

3See Resp't Lewis County's Mot. to Strike Pet'rs Answer to Amicus Curiae

Mem. of Foundation.

4The Foundation contends, and the concurrence agrees, that the public duty

doctrine wrongly undermines statutory waiver of sovereign immunity under

RCW 4.96.010 by judicially imposing what it contends is a second layer of

tort liability immunity for government entities.  Mrs. Cummins did not make

this argument to the trial court, to the Court of Appeals, or to this court

in her petition for review.  We, thus, decline to consider the Foundation's

request.  The Foundation is not a party to this case, and its interest in

the outcome of it is merely tangential.  Under case law from this court, we

address only claims made by a petitioner, and not those made solely by

amici.  Mains Farm Homeowners Ass'n v. Worthington, 121 Wn.2d 810, 826, 854

P.2d 1072 (1993).  This opinion, therefore, addresses only those claims

raised by Mrs. Cummins in her petition for review.

5Lewis County argues that Mrs. Cummins has failed to show that the

deceased, Mr. Cummins, was the "heart attack" caller.  However, on summary

judgment, all evidence and inferences are viewed in a light most favorable

to the nonmoving party.  That being the case, we must assume that Mr.

Cummins placed the "heart attack" call.

6We note at this point that Mrs. Cummins points to no express statutorily

imposed duty applicable to Lewis County under these circumstances.  Rather,

she asserts that RCW 38.52.500 provides a 911 medical-emergency caller with

an implicit promise that the government entity fielding the call will

"provide a rapid response."  Pet. for Review at 12.  Lewis County counters

that under the controlling case law Mrs. Cummins's argument that the

government's implicit promise under the E911 statute to promptly dispatch

medical aid to save the caller's life cannot be a basis for a court to

impose municipal liability.  This is also what the appeals court held.

Citing to this court's decision in Honcoop as its authority, Division Two

stated that an individual cannot rely on broad statements of legislative

intent to support a tort action against a public entity.  Cummins, 124 Wn.

App. at 255 (citing Honcoop v. State, 111 Wn.2d 182, 188, 759 P.2d 1188

(1988)).  We concur with the appeals courts' statutory duty analysis.  At

most, the E911 statute imposes upon Washington's counties an obligation to

have in place an enhanced 911 system by December 31, 1998.  See RCW

38.52.510.  Mrs. Cummins does not contend that Lewis County breached its

statutory duty to have in place an E911 system, and the record shows that

the county did, in fact, have such a system in place and operating at the

time Mr. Cummins placed the 911 call at issue.  Therefore, we discern no

basis in the E911 statute upon which to conclude Lewis County had an

actionable statutory duty to Mr. Cummins.

7The exceptions are (1) legislative intent, (2) failure to enforce, (3) the

rescue doctrine, and (4) a special relationship.  Babcock, 144 Wn.2d at

786.

8See, e.g., Bratton, 145 Wn.2d at 577 (analyzing duty owed by 911 to send

police); Babcock, 144 Wn2d at 785 (analyzing duty owed by fire department

when fire fighter communicated with plaintiffs in person); Mull v. City of

Bellevue, 64 Wn. App. 245, 823 P.2d 1152 (1992) (analyzing government duty

owed to building owner).

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