McClintock v. West (2013) 219 Cal.App.4th 540, involved divorce proceedings in which the court appointed a GAL to act on behalf of a father who had been hospitalized for depression. The GAL made decisions regarding the division of assets and child custody, and the father later sued, claiming the GAL's actions led to the loss of financial assets and custody rights with respect to his children. Father argued that his GAL was not entitled to quasi-judicial immunity because she was not acting as a neutral, but rather was tasked with making decisions on his behalf. The McClintock court instead examined whether the GAL's role was "'"intimately related to the judicial process"'" (McClintock, supra, at p. 551.) Because the GAL was a court-appointed officer acting under the trial court's supervision, her role was related to the judicial process and she was therefore entitled to quasi-judicial immunity. (McClintock, supra, at pp. 551-553.) The policy considerations stated in Howard weighed strongly in favor of finding quasi-judicial immunity in McClintock. The court questioned whether any qualified person would accept appointment as a GAL knowing he or she would be subject to post hoc second-guessing and potential "liability for causes of action ranging from negligence to intentional interference with prospective economic advantage, resulting in the potential for years of litigation and financial liability greater than her entire fee for handling the case . . . ." (Id. at p. 551.) The court also noted the risk of litigation or liability would impact any GAL's ability to carry out the duties for which he or she was appointed. However, quasi-judicial immunity does not leave GALs completely unaccountable. Rather, GALs must still act within their scope of authority, and are both appointed by and supervised by the court, and subject to removal if they are not carrying out their duties in a responsible manner. (Id. at p. 552.)