Police departments and officers in Texas are heavily protected from failure-to-protect lawsuits, making it difficult for victims of domestic violence to seek justice. The combination of sovereign immunity, qualified immunity, and the public duty doctrine creates significant barriers for victims. The Texas Tort Claims Act limits the ability to sue police for failing to protect, and constitutional claims have largely failed to overcome qualified immunity. The Public Duty Doctrine states that police officers have no duty to individuals unless they create the danger. Recommendations include modifying domestic violence statutes and collecting evidence for Equal Protection cases.