Does a court's order for a surety to release a defendant's bond materially increase the surety's risk on the bond?

between the defendant and the surety.' " (Id. at p. 323, quoting United States v. Galvez-Uriarte (9th Cir. 1983) 709 F.2d 1323.) Thus, the Western court concluded that the trial court's order materially increased the surety's risk on the bond because the action authorized the breach of an implied covenant between the defendant and the surety that he would not depart the county, and also placed the defendant beyond the reach of both the surety and domestic law enforcement agencies. (Western, supra, at pp. 323-324.) The court reasoned: