Bell v. State

A plaintiff in a negligent parole supervision action must prove the inadequate supervision proximately caused the complained-of injuries.

Here Barbara Bell, abducted and raped by a sex offender on parole, sued the State of Washington for failing to use reasonable care to supervise the parolee. The jury found the State breached its duty to reasonably supervise but also found that breach was not a proximate cause of the injury. The Court of Appeals affirmed. We accepted review to consider whether the trial court erred when it (1) refused Bell’s proposed jury instructions on the standard of proof…