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A parolee is in no sense an agent of the parole board. When a victim's death is too remote a consequence of the parole officers' action, the officers are not responsible under the federal civil rights law. Although a § 1983 claim has been described as "a species of tort liability," it is perfectly clear that not every injury in which a state official has played some part is actionable under that statute.
Appellants' decedent, a 15-year-old girl, was murdered by a parolee five months after he was released from prison despite his history as a sex offender. Appellants brought an action in a California court under state law and 42 U. S. C. § 1983, claiming that appellee state officials, by their action in releasing the parolee, subjected the decedent to a deprivation of her life without due process of law and were therefore liable in damages for the harm caused by the parolee. The trial court sustained a demurrer to the complaint. The California Court of Appeal affirmed, holding that a California statute granting public employees absolute immunity from liability for any injury resulting from parole-release determinations provided appellees with a complete defense to appellants' state-law claims, and that appellees enjoyed quasi-judicial immunity from liability under 42 U. S. C. § 1983. Certiorari was granted.
Could state officials be held liable for the injury resulting from parole-release determinations?
The Court affirmed the decision of the appellate court, holding that the California immunity statute was not unconstitutional under the Fourteenth Amendment when applied to defeat the tort claim arising under state law, such statute not having deprived the murder victim of due process of law by condoning a parole decision leading indirectly to the individual's death, and not having brought about an invalid deprivation of property, even assuming the immunity defense could be construed as depriving the victim's survivors of their "property" interest in a cause of action for wrongful death. The Court further held that the survivors of the murder victim had not alleged a claim for relief under 42 USCS 1983 against the state officials by claiming that the officials subjected the victim to a deprivation of her life without due process of law since the action of the parolee was not state action for purposes of the Fourteenth Amendment. Moreover, the Court ruled that the officials did not "deprive" the victim of life within the meaning of the Fourteenth Amendment regardless of whether, as a matter of state tort law, the parole board had a "duty" to avoid harm to the victim, or proximately caused the death. According to the Court, the death was too remote a consequence of the officials' action to hold them responsible under 1983.