Washington Law Review


In a recent decision, Savage v. State, the Washington Supreme Court declined to extend a parole officer's personal qualified immunity to the State where the plaintiff alleged negligent supervision of a parolee. This Note examines the effects of the Savage decision on the scope of sovereign immunity in Washington. It argues that the court has needlessly confused the boundaries of sovereign immunity, and should act either to abolish all judicially created limits on state liability, or create a clear test to determine under what circumstances an underlying immunity will be extended to a government employer sued on a respondeat superior theory of liability.

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