Grimm v. Arizona Bd. of Pardons and Paroles
In Grimm v. Arizona Bd. of Pardons and Paroles, 115 Ariz. 260, 564 P.2d 1227 (1977), the court retreated from its previous extension of absolute judicial immunity to public officials for their discretionary acts. Id. at 265-66, 564 P.2d at 1232-33.
In light of the increasing power wielded by governmental officials without corresponding accountability or checks on that power, the court reasoned that qualified immunity for such officials was appropriate. Grimm, 115 Ariz. at 266, 564 P.2d at 1233.
Thus, the court concluded that "absolute immunity for nonjudicial, nonlegislative officials is outmoded and even dangerous." Id.