In Clements v. Barnes, 834 S.W.2d 45, 46, 35 Tex. Sup. Ct. J. 928 (Tex. 1992), the Court granted derived judicial immunity to court-appointed bankruptcy trustees, concluding that they function as an "arm of the court," and thus protection from liability was appropriate. The Court did not, however, elaborate on or discuss how to determine when a court officer is entitled to the benefits of derived judicial immunity.