Sixth Circuit precedent establishes a few relevant propositions. First, as a general matter, the affirmative act requirement has teeth and is not something to be dismissed as semantics when the evidence shows that the standard has not been met. See id. at 465 (listing seven cases in the past eight years in which the Sixth Circuit did not find an affirmative act). Second, it is not an affirmative act merely to return a victim to a dangerous situation. See Bukowski v. City of Akron, 326 F.3d 702, 710 (6th Cir.2003)(following DeShaney, 489 U.S. at 201, 109 S.Ct. 998). Third, attempts by state officials to improve safety do not become actionable affirmative acts merely because harm ends up befalling an affected person. See Cartwright v. Marine City, 336 F.3d 487, 493-94 (6th Cir.2003)(<HOLDING>). Applying those principles to the facts of
holding that a shoulder purse carried by a person at the time he is stopped lies within the scope of a warrant authorizing the search of his person holding that a state agency is not a person subject to suit under federal false claims act holding that transporting a person from shoulder of highway to convenience store where that person is later raped is not actionable under statecreated danger theory because the officials act did not increase the risk holding that a state is not a person within the meaning of  1983 holding that theft from the person is not a crime of violence