Christoffersen v. State, Court Custody Investigator's Office

Summary

The Alaska Supreme Court affirmed summary judgment for the State in a damages action arising from a court-appointed custody investigator's failure to immediately report or warn about allegations of a child's sexual misconduct. The court held that custody investigators performing court-appointed investigative duties are entitled to absolute quasi-judicial immunity and that the immunity extends to the State against vicarious liability claims. The court therefore did not reach the alternative issue of whether the investigator owed an actionable tort duty.

Holdings

1. A custody investigator performing duties pursuant to employment by or a contract with the Alaska Court System's Custody Investigator's Office is a quasi-judicial officer and is entitled to absolute quasi-judicial immunity from suits arising from performance of those duties.
2. When a court-appointed custody investigator is absolutely immune from suit for conduct performed in that capacity, the State cannot be held vicariously liable for the investigator's conduct.

Questions Presented

1. Whether a court-appointed custody investigator is entitled to absolute quasi-judicial immunity from civil suits arising from the performance of the investigator's duties.
2. Whether absolute quasi-judicial immunity applicable to the custody investigator extends to the State for a vicarious-liability claim based on the investigator's conduct.

Disposition

affirmed