In the Martinez and Thompson cases, the California Supreme Court, which has been notoriously lenient toward criminals and their rights, took little notice of victims' rights. In these cases, the court held that custodial officials had absolute immunity, although both involved gross negligence on the part of officials in releasing highly dangerous offenders into communities where they sexually assaulted and murdered child victims. Conversely, the Arizona Supreme Court, which has been conservative on law and order issues, has taken a lead in the area of victims' rights. In Grimm, the court held that public officials should be held accountable for misconduct or gross negligence. While difficulty in defining gross negligence has been advanced as an argument for granting sovereign immunity to officials, it could not be disputed in these three cases that the officials were grossly negligent. The additional concern that accountability would deter people from serving on parole boards can be countered as well: people who feel they should never be held accountable should not be placed in positions in which their decisions can be life-threatening. Those who take charge of dangerous individuals have a duty to control them. 14 notes and references.