AN INDIVIUAL WHO HAS BEEN INJURED AS THE RESULT OF A PAROLEE'S CRIMINAL ACTS AND WHO WISHES TO SUE THE PAROLE BOARD MUST FIRST DISTINGUISH THE PARTICULAR THEORY OF ACTION. POSSIBILITIES INCLUDE CAUSES OF ACTION BASED ON THE IMPROPER RELEASE OF THE PAROLEE, A PAROLE OFFICER'S FAILURE TO DISCLOSE THE PAROLEE'S VIOLENT BACKGROUND, AND FAILURE OF A PAROLE OFFICER TO SUPERVISE ADEQUATELY THE PAROLEE'S ACTIVITIES. IN QUASI-JUDICIAL IMMUNITY, IT IS CONSIDERED ESSENTIAL TO THE PROPER ADMINISTRATION OF JUSTICE THAT THOSE WHO DETERMINE AN INDIVIDUAL'S ELIGIBILITY FOR PAROLE SHOULD NOT CONCERN THEMSELVES WITH THE POTENTIAL FOR SUBSEQUENT PERSONAL LIABILITY. OTHER OBSTACLES, IN ADDITION TO QUASI-JUDICIAL IMMUNITY, MUST BE OVERCOME BEFORE THE IMPOSITION OF PAROLE BOARD LIABILITY WILL RESULT FROM THE DECISION TO RELEASE AN INDIVIDUAL ON PAROLE. THESE BARRIERS INVOLVE THE CONCEPTS OF DUTY AND PROXIMATE CAUSATION. A PLAINTIFF WHO ALLEGES FAILURE ON THE PART OF A PAROLE OFFICER TO DISCLOSE THE PAROLEE'S VIOLENT BACKGROUND STANDS A BETTER CHANCE OF RECOVERY THAN A PLAINTIFF RELYING ON NEGLIGENT RELEASE THEORY. WHEN A PLAINTIFF BASES A CAUSE OF ACTION UPON FAILURE OF A PAROLE OFFICER TO SUPERVISE THE PAROLEE'S ACTIVITIES, THE POSSIBILITY OF RECOVERY IS AGAIN TENUOUS. A PAROLE OFFICER SHOULD BE CHARGED WITH THE RESPONSIBILITY OF WARNING A POTENTIAL EMPLOYER OF THE LATENT DANGER A CLIENT REPRESENTS, BUT THIS RESPONSIBILITY SHOULD BE LIMITED BY CONCOMITANT DUTIES OF THE EMPLOYER. THE DECISION IN THE RIESER VERSUS DISTRICT OF COLUMBIA CASE IS SIGNIFICANT SINCE LIABILITY WAS IMPOSED, IN PART, BECAUSE OF THE PAROLE OFFICER'S FAILURE TO SUPERVISE CLIENT ACTIVITIES, A FUNCTION THAT MANY COURTS REFUSE TO REVIEW. THE CASE EXPANDED THE POTENTIAL NUMBER OF INDIVIDUALS TO WHOM A PAROLE BOARD MAY OWE AN ACTIONABLE DUTY OF CARE AND CLARIFIED THE PAROLE OFFICER'S DUTY TO DISCLOSE THE PAROLEE'S BACKGROUND TO A POTENTIAL EMPLOYER. CASE LAW IS CITED. (DEP)