Her behavior throughout the process—her participation in the abduction, her presence at the household, her appearance at the Concord parole office on August 26—reflects a sustained and active commitment to maintaining the conditions of captivity. The characterization of her as a secondary actor should not obscure the significance of her active participation.
—
## The State Settlement: What It Covered
The $20 million settlement that California approved in 2010 was, at that time, the largest settlement of its kind in a case involving parole supervision failures in California history. The size reflected both the duration of the failure—nearly two decades—and the severity of the documented deficiencies catalogued in the Inspector General’s report.
Settlements of this kind in California require legislative approval when they exceed certain thresholds. The legislature’s approval of the $20 million settlement indicated a broad institutional recognition that the state bore significant responsibility for what had happened.
The settlement covered the period of California state parole supervision, which had begun in 1999. It did not resolve the federal claims, which were subject to separate litigation under federal standards. The federal lawsuit pursued claims arising from the federal parole supervision that had been in effect prior to and at the time of the 1991 abduction—the period when Garrido was on federal parole following his release from federal custody in 1988.
The federal claim encountered different legal standards. Under the Federal Tort Claims Act and related federal law, the government’s liability for the actions of a supervised individual requires a specific kind of legal relationship between the government’s supervisory conduct and the harm that occurred. The Ninth Circuit’s 2-1 ruling in 2016 applied these standards and found that “there was no way to anticipate she would become his victim”—a legal conclusion that drew on the specific standards governing federal government liability rather than on a factual finding that the federal parole supervision had been adequate.