AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Plaintiff, in a domestic relations matter involving his child, requested the appointment of Defendant Kathy Brandt as guardian ad litem for the child. Subsequently, the Plaintiff sought all correspondence related to the case from Brandt, who then obtained a protective order to prevent disclosure. The Plaintiff later made an Inspection of Public Records Act (IPRA) request for the same records, which was denied based on several grounds, including the protective order and quasi-judicial immunity. The Plaintiff filed an action for a declaratory judgment to order the production of the records, which was dismissed by the district court.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the guardian ad litem's records are subject to IPRA as they act as an "arm of the court" and that none of the exceptions to IPRA apply to the guardian's records.
• Defendants: Contended that the protective order prohibits disclosure of the records to the Plaintiff and that, to the extent the Second Judicial District Court (SJDC) possesses communications between the court and Brandt, the judicial deliberation privilege protects those records from public disclosure.

Legal Issues

• Whether the guardian ad litem’s records are subject to IPRA.
• Whether the protective order precludes disclosure of the guardian ad litem’s records to the Plaintiff.
• Whether the judicial deliberation privilege protects communications between the guardian ad litem and the district court judge from public disclosure.

Disposition

• The district court's dismissal of the Plaintiff's complaint was affirmed.

Reasons

• The Court held that the protective order precludes disclosure of the guardian ad litem’s records to the Plaintiff under the circumstances presented. It was determined that the protective order, issued by a court with jurisdiction, must be obeyed until modified or reversed, and that IPRA does not supersede such an order. Additionally, the Court found that the judicial deliberation privilege protects communications between the guardian ad litem and the district court judge from public disclosure, as the guardian ad litem functions as an extension of the court in specific cases. The Court did not address whether the quasi-judicial immunity recognized in Kimbrell protects the guardian ad litem from an IPRA enforcement suit, whether the Plaintiff properly named the guardian ad litem as a defendant in this IPRA action, or whether the Plaintiff’s IPRA action is an improper collateral attack on the protective order (paras 1-18).