Lythgoe v. Guinn
In Lythgoe v. Guinn, 884 P.2d 1085, 1086 (Alas, 1994) a court-appointed psychologist was sued for negligence by a mother who lost a custody dispute after the defendant recommended granting custody to the father.
Under the terms of the order appointing the psychologist, the parties were to share the fees and costs of the psychologist. Although the defendant's report was ultimately stricken from the record after an in camera review of her qualifications and the credibility of her testimony, the trial court nonetheless dismissed the plaintiff's claim, finding that the defendant's "actions fell within the scope of quasi-judicial immunity." Id.
The Supreme Court of Alaska affirmed the trial court's decision, holding that psychologists appointed by the court to perform custody evaluations are "an arm of the court" who serve an integral part of judicial process and are thus immune from tort liability. Id. at 1088.