In February 2015, the San Francisco Sheriff’s Dep’t adopts policy not to honor requests from ICE to be notified in advance about the release of undocumented aliens without a court order. In March 2015, ICE asks to be notified before the release of five-time deportee who’d served a 46-month drug sentence. Per the policy, the deportee is released without notice to ICE. Shortly thereafter, he steals a gun and kills a woman. Can the City and the Sheriff by held liable by the victim’s parents? Ninth Circuit: These are tragic facts, but California law grants immunity to the government defendants.