Nichols v. Fahrenkamp

Defendant attorney was appointed as guardian ad litem (GAL) for minor plaintiff as to settlement for injuries she suffered in motor vehicle accident. Eight years after settlement, plaintiff sued her mother who court had named guardian of her estate, alleging that she used nearly $80,000 of settlement funds for her own benefit. Plaintiff then sued GAL for failing to adequately monitor and audit mother's requested expenditures. GALs who submit recommendations to the court on a child's best interests are protected by quasi-judicial immunity. (KARMEIER, THOMAS, KILBRIDE, BURKE, THEIS, and NEVILLE, concurring.)