Craviolini v. Scholer & Fuller Associated Architects
In Craviolini v. Scholer & Fuller Associated Architects, 89 Ariz. 24, 27, 357 P.2d 611, 613 (1961), the Arizona Supreme Court explained that arbitrators in private, contractual arbitrations exercise "quasi-judicial functions."
The court stated that arbitrators are therefore protected by an absolute immunity:
"The immunity in question here is one bestowed by public policy on those people who, by office or by contract, are called upon to act as judges. It is in every real sense a judicial immunity. It attaches to every act done in the judicial capacity. . . . In the role of arbitrator . . . goes the cloak of immunity." Id. at 28, 357 P.2d at 614.