What is the test for liability for negligence relating to the actions of Officer Garrow?

liability for negligence relating to the actions of Officer Garrow, Plaintiff must demonstrate "the officer took affirmative action which contributed to, increased, or changed the risk which would have otherwise existed" or alternatively establish "the requisite factors to a finding of special relationship ..." Stout, 148 Cal. App. 3d at 945; see also Williams v. State of California, 34 Cal. 3d 18, 27 (1983) (because officers had not created the peril of harm to plaintiff, they were under no duty to take affirmative action to prevent harm in the absence of a special relationship).