Roy Sears began physically abusing Michele Okin after the birth of their first child. (1) Okin sought police protection from Sears on multiple occasions. On one occasion when a police officer intervened and arrived at their home after Sears had beaten Okin, the officer did not question or arrest Sears, choosing instead to discuss football with Sears. At that time, Sears was beating Okin every day. The domestic violence continued after the officer left their home. Can Okin or other women in her situation bring a claim against police officers who act in similar ways for the violation of their substantive due process rights, and if so, under what standard? Violence between intimate partners, perpetrated primarily against women, is a major societal ill. (2) It is the "single greatest cause of injury to women in America--more than muggings, rapes, and car accidents combined." (3) A woman in the United States is more likely to be killed by her partner than by any other assailant." (4) Domestic violence has long been considered a private matter rather than a public one, and many police officers still treat domestic violence as an issue that should be addressed in the privacy of the home. (5) The police sometimes fail to take steps to protect women from domestic violence, and in some cases, police action can increase victims' risk from domestic violence.