Cariol Horne served Buffalo, New York, as a police officer for twenty years before being fired for stopping Gregory Kwiatkowski, her colleague and fellow police officer, from choke holding a handcuffed African-American man during an arrest in 2006. During this encounter, Ms. Horne was physically assaulted by Gregory Kwiatkowski, leading to a physical and psychological impact on Cariol Horne.

After an internal investigation, the Buffalo Police Department did not find wrongdoing by Kwiatkowski. In 2008, she was faced with 13 departmental disciplinary charges, and after a public hearing, 11 were sustained. She was fired in May 2008, months before she was eligible for a full pension.

In June 2020, the law firm Kirkland & Ellis accepted Cariol’s case, and filed a lawsuit on her behalf to restore her pension by overturning the termination of her employment. In June 2020, Horne announced the proposed legislation "Cariol's Law," to require officers to intervene against excessive force and to protect intervening officers from retaliation. In September 2020, the Buffalo Common Council passed "Cariol's Law, and in October 2020, the mayor of Buffalo signed "Cariol's Law" as the Duty to Intervene law.

In 2021, a New York State Supreme Court vacated the 2010 court ruling, and awarded her back pay and her pension.