Nystedt v. Nigro, No. 12-1245 (1st Cir. 2012)Annotate this Case
This case required the First Circuit Court of Appeals to explore the parameters of the doctrine of quasi-judicial immunity. The underlying litigation was a will contest turned conspiracy case. The plaintiff prevailed in probate court after two and a half years of legal wrangling. By the time Plaintiff was found to be the sole lawful heir of the decedent, the estate's assets were depleted. Seeking retribution, the plaintiff sued several persons involved in the will contest, alleging a wide-ranging conspiracy. In a preliminary ruling, the district court concluded that two of the defendants, a lawyer who had served as a court-appointed discovery master and the lawyer's firm, were immune from suit by reason of quasi-judicial immunity. The court certified this ruling as a partial final judgment. The First Circuit affirmed, holding (1) the district court did not err in certifying the ruling; and (2) the court-appointed discovery master was entitled to share in the judge's immunity from suit, and the law firm whose partner enjoyed quasi-judicial immunity was entitled to share in that immunity for helping the partner to perform his judicial tasks.