Supreme Court of Virginia

Constance P. Fox v. Roy S. Custis

September 23, 1988236 Va. 69

Summary

The Court affirmed dismissal of the plaintiffs' negligence actions against parole officers arising from a parolee's subsequent violent crimes. It held that the officers neither took charge of nor exercised sufficient control over the parolee to create a special relationship imposing a duty to control his conduct, and that the governing statute gave them discretion rather than requiring automatic arrest for every parole violation.