Martinez v. California
Annotate this Case
444 U.S. 277 (1980)
U.S. Supreme Court
Martinez v. California, 444 U.S. 277 (1980)
Martinez v. California
Argued November 5, 1979
Decided January 15, 1980
444 U.S. 277
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.
1. The California immunity statute is not unconstitutional when applied to defeat a tort claim arising under state law. Pp. 444 U. S. 280-283.
(a) The statute, which merely provides a defense to potential state tort law liability, did not deprive appellants' decedent of her life without due process of law because it condoned a parole decision that led indirectly to her death. A legislative decision that has an incremental impact on the probability that death will result in any given situation cannot be characterized as state action depriving a person of life just because it may set in motion a chain of events that ultimately leads to the random death of an innocent bystander. P. 444 U. S. 281.
(b) Even if the statute can be characterized as a deprivation of property, the State's interest in fashioning its own rules of tort law is paramount to any discernible federal interest, except perhaps an interest in protecting the individual citizen from wholly arbitrary or irrational state action. The statute is not irrational, because the California Legislature could reasonably conclude that judicial review of parole decisions "would inevitably inhibit the exercise of discretion," and that this inhibiting effect could impair the State's ability to implement a parole program designed to promote rehabilitation of inmates,
as well as. security within prisons by holding out a promise of potential rewards. Pp. 444 U. S. 281-283.
2. Appellants did not allege a claim for relief under federal law. Pp. 444 U. S. 283-285.
(a) The Fourteenth Amendment protected appellants' decedent only from deprivation by the State of life without due process of law, and although the decision to release the parolee from prison was action by the State, the parolee's action five months later cannot be fairly characterized as state action. Pp. 444 U. S. 284-285.
(b) Regardless of whether, as a matter of state tort law, the parole board either had a "duty" to avoid harm to the parolee's victim or proximately caused her death, appellees did not "deprive" appellants' decedent of life within the meaning of the Fourteenth Amendment. P. 444 U. S. 285.
(c) Under the particular circumstances where the parolee was in no sense an agent of the parole board, and the board was not aware that appellants' decedent, as distinguished from the public at large, faced any special danger, appellants' decedent's death was too remote consequence of appellees' action to hold them responsible under § 1983. P. 444 U. S. 285.
85 Cal.App.3d 430, 149 Cal.Rptr. 519, affirmed. STEVENS, J., delivered the opinion for a unanimous Court.