Suprenant v. MulcroneAnnotate this Case
Pro se Plaintiff Robert Suprenant appealed a superior court order that dismissed his claims against Defendant Deborah Mulcrone under the doctrine of absolute quasi-judicial immunity. Defendant was the guardian ad litem for Plaintiff's son in a contested case between Plaintiff and the son's mother. Defendant was appointed to investigate how Plaintiff and his son's mother should divide parenting time and residential responsibility for their son. Defendant stated in her report that although it was "commendable" that Plaintiff had no criminal charges since 1994, his failure to disclose his prior charges was "troubling." Plaintiff filed suit against Defendant alleging those statements in her report were negligently made and breached an implied contract with Plaintiff to observe "reasonable standards of care and fair dealing." Upon review, the Supreme Court concluded that Defendant was entitled to absolute immunity for her acts. Accordingly, the Court upheld the trial court's dismissal of Plaintiff's lawsuit.