Delbridge v. Office of Public Defender

In Delbridge v. Office of Public Defender, 238 N.J. Super. 288, 301-02, 569 A.2d 854, 860-61 (Law Div.1989), plaintiffs were the parents of children who had been removed from their home in DYFS abuse and neglect proceedings. As a part of those proceedings, the trial court appointed a law guardian to represent the interests of the children in the proceedings and appointed counsel for the adults. In subsequent proceedings, the adults sought to sue those individuals and others on a variety of legal theories arising out of the proceedings. As to the attorneys who had been appointed to serve as law guardians, the court held that the doctrine of absolute immunity protected them from any suits on any theories. 238 N.J. Super. at 299-300, 569 A.2d at 859-60. The judge in Delbridge relied on variety of decisions holding that judicial officers are absolutely immune and discussed at length the public policy rationale for judicial immunity. Moreover, citing Cashen v. Spann, 66 N.J. 541, 334 A.2d 8, cert. denied, 423 U.S. 829, 96 S. Ct. 48, 46 L. Ed. 2d 46 (1975), the court pointed out that "court officers exercising judicial functions are absolutely immune," Delbridge v. Office of Public Defender, supra, 238 N.J. Super. at 300, 569 A.2d at 860, and commented that even in the face of a claim of malice or an allegation of corruption, such immunity is absolute. Ibid. Reasoning that the law guardians functioned as officers of the court and were an integral part of the judicial process, the court held that they were immune from suit. As the court there noted, "those integrally related to the judicial process should not be subject to 'private prosecutions whenever . . . disappointed suitors might dictate' . . . . To do so would interfere with 'their independence and destroy their authority.'" Id. at 301, 569 A.2d at 861. In Delbridge, while the public defenders who represented the parents enjoyed qualified judicial immunity, they were not immune from claims of conspiracy, intentional misconduct and legal malpractice. Id.