In Martinez v. California (1980) 444 U.S. 277, a teenage girl was murdered by a parolee. Her survivors sued the parole board under section 1983 and alleged that when it released the parolee, it subjected the girl to a deprivation of life without due process of law. The court rejected the theory on the grounds that the girl's death was too remote a consequence of the parole board's actions. In particular, the court noted that the parolee was not an agent of the parole board, and the parole board was not aware that the girl faced any special danger. (Martinez, supra, 444 U.S. at pp. 284--285.)