DALLIN FORT V. STATE OF WASHINGTON, No. 21-35265 (9th Cir. 2022)

Plaintiff brought an action against the State of Washington, the Review Board, and its members (State Defendants). Plaintiff specifically sought review of the district court’s decision that the Review Board’s actions relating to Plaintiff’s release determination hearing fall squarely within the quasi-judicial nature of the Review Board’s functions, and that Defendants are entitled to quasi-judicial immunity.
 
The Ninth Circuit affirmed the district court’s dismissal of an action alleging false imprisonment, negligence and civil rights violations arising from actions taken by the Washington Indeterminate Sentencing Review Board in scheduling Plaintiff’s hearing.
 
The Indeterminate Sentencing Review Board is a parole board created by the Washington State Legislature that is tasked with reviewing the sentences of convicted sex offenders to determine whether the offenders should be released on parole. The court held that under the facts of this case and in the context of the proceedings as a whole, the Review Board’s setting of hearings pursuant to Wash. Rev. Code Section 9.95.420 was “part and parcel of the decision process,” thereby warranting quasi-judicial immunity. The court rejected Plaintiff’s contention that the scheduling of the hearing was an administrative task not entitled to quasi-judicial immunity. Because the court agreed with the district court that the Review Board was entitled to quasi-judicial immunity, Plaintiff was unable to state a plausible claim for relief against the state Defendants.