In Fleming v. Asbill, 326 S.C. 49, 483 S.E.2d 751 (1997), the Court held individuals appointed as guardians ad litem in private custody proceedings are entitled to absolute quasi-judicial immunity for acts performed within the scope of their appointment. Fleming, 326 S.C. at 57, 483 S.E.2d at 755-56. The court noted the role of a guardian ad litem is to serve as a representative of the court and to assist it in protecting the best interests of the child. Id. at 54-55, 483 S.E.2d at 754. The court recognized that immunity for acts performed within the scope of a guardian ad litem's appointment is necessary to protect the guardian from the threat of lawsuits by disgruntled parents. Id. at 57, 483 S.E.2d at 755. The Fleming court noted that, under a grant of absolute quasi-judicial immunity, a guardian ad litem in a private custody dispute could not be found liable for acts of gross negligence or even recklessness in the performance of her duties. Id. at 56, 483 S.E.2d at 755. However, the court explained certain safeguards exist along with the grant of immunity: "First, the immunity would not protect guardians ad litem for actions beyond the scope of their duties. Thus, for example, if a guardian abuses a child, she would be liable because her actions would fall outside her duties as guardian. Second, the accountability of the guardian ad litem is preserved in various ways. For example, the opposing party may cross-examine the guardian ad litem and any witnesses whose testimony form the basis of the guardian's recommendation. This accountability is further ensured through: (1) the appointing court's oversight of the guardian ad litem's discharge of duties; (2) the parents' ability to move the court for termination of the guardian; (3) the court's prerogative to reject the recommendations of the guardian; (4) judicial review of family court decisions relying on a guardian's recommendations." Id. at 56-57, 483 S.E.2d at 755.