Victoria Taggart, Appellant v. the State of Washington, Respondent; Shane Sandau, Appellant, v. the State of…

Summary

The court held that the parole board was absolutely immune for its quasi-judicial release decision, but parole officers were only qualifiedly immune for supervisory conduct outside judicial or quasi-judicial proceedings. It further held that the public duty doctrine and proximate-cause principles did not justify dismissing the negligent-supervision claims because parole officers may owe a duty to persons foreseeably endangered by parolees and a jury could find causation. The negligent-release claim was affirmed as dismissed, while the negligent-supervision claims were reversed and remanded; Justice Utter concurred in defending the majority's analysis, and Justice Guy would have extended absolute immunity to parole officers and affirmed dismissal.