Tarter v. State, 68 N.Y.2d 587 (1986)
Parole board members are entitled to absolute immunity from tort liability when performing quasi-judicial functions such as deciding whether to grant parole, even if those decisions are alleged to be negligent or in violation of established procedures.
Summary
This case addresses whether the State and Parole Board can be held liable for negligently releasing dangerous prisoners who then inflict harm on the public. The Court of Appeals held that parole release decisions are quasi-judicial and thus protected by absolute immunity, shielding the State from tort liability. This immunity is crucial to allow parole board members to make impartial decisions without fear of civil retribution. The court also found that there was no special duty owed to the claimants and no specific assurances of protection.
Facts
Two separate claimants were severely injured by individuals released on parole. Myrna Tarter was shot by Michael Montgomery, who had a prior conviction for a similar shooting. William Tyner was shot by Leslie Pastrana, who had previously attacked a police officer. Both parolees committed their violent acts shortly after being released. Tarter and Tyner sued the State, alleging negligence in the parole boards decisions to release Montgomery and Pastrana.
Procedural History
In Tarter, the Court of Claims initially dismissed the claim for insufficient factual allegations but was modified by the Appellate Division. The Court of Appeals then reversed. In Tyner, the Court of Claims granted the claimant’s motion to file a late claim, which was affirmed by the Appellate Division. The Court of Appeals reversed this decision as well.
Issue(s)
Whether the State and the New York State Board of Parole may be held liable for negligently releasing dangerous prisoners on parole, where the parolees inflict serious injuries upon members of the public.
Holding
No, because parole release decisions are quasi-judicial in character, the State and its employees are absolutely immune from tort actions arising from such decisions.
Court’s Reasoning
The Court of Appeals reasoned that parole board members perform a quasi-judicial function when deciding whether to grant parole. This function requires weighing evidence, assessing the relative importance of various factors, and making a discretionary disposition. The court emphasized that “[t]he functions of the impartial Board in deciding whether to grant parole are classically judicial tasks.” The court relied on the principle of judicial immunity, which protects judges from civil suits arising from their judicial acts, even if those acts are alleged to be erroneous or motivated by improper motives. The court extended this immunity to parole board members because their functions are analogous to those of judges. The court stated that “[l]ogically, other neutrally positioned government officials, regardless of title, who are delegated judicial or quasi-judicial functions should also not be shackled with the fear of civil retribution for their acts.” The court noted, “It is the peculiar nature of the duties of the Board of Parole with respect to the weighing of evidence, deciding the relative importance of the determining factors and the ultimate discretionary disposition which render it so.”
The Court also rejected the argument that Executive Law § 259-i(5), which states that any action by the board “shall be deemed a judicial function and shall not be reviewable if done in accordance with law,” only affords immunity when the Board acts in accordance with the law. The Court found this argument irrelevant to the question of the Parole Board’s liability to third parties, emphasizing that the ability to review a decision for errors of law is distinct from immunity from civil suits.
Finally, the Court dismissed any claim based on negligent supervision because the claimants failed to allege both a special duty to protect them as identified individuals and reliance on specific assurances of protection.