Since Dwyer, Pennsylvania courts have extended quasi-judicial immunity to other administrative officials acting in an adjudicatory capacity. See Myers v. Dept. of Labor and Indus., 312 Pa.Super. 61, 458 A.2d 235, 238 (1983) (holding that a workmen's compensation referee was acting as a quasi-judicial officer, and was absolutely immune from liability for his statutorily assigned tasks); Urbano v. Meneses, 288 Pa.Super. 103, 431 A.2d 308, 311 (1981) (holding that zoning board members, when ruling on an individual application for a zoning permit, were acting in a quasi-judicial capacity and were entitled to quasi-judicial immunity). Quasi-judicial immunity has also been extended to witnesses testifying at an administrative adjudicatory hearing.
.Id. (citing Myersv.Cam. Dep't of Lab. & Indus., 312 Pa.Super. 61, 458 A.2d 235 (1983)).
See also Clodgo by Clodgo v. Bowman, 601 A.2d 342 (Pa. Super. 1992) (judicial immunity insulated a court-appointed medical expert witness from liability premised upon malpractice); Panitz v. Behrend, 632 A.2d 562 (Pa. Super. 1993) (applying testimonial immunity to expert witnesses); Logan v. Lillie, 728 A.2d 995, 998 (Pa. Cmwlth. 1999) (immunity applied to a child custody conference officer who, pursuant to the Pennsylvania Rules of Civil Procedures, conducted a child custody settlement conference and made recommendations to a judge on whether to suspend a father's custody over a child); Reuben v. O'Brien, 496 A.2d 913 (Pa. Cmwlth. 1985) (judicial immunity extended to township constable whose actions were taken at direction of district judge); Myers v. Dept. of Labor and Indus., 458 A.2d 235 (Pa. Super. 1983) (holding that a workers' compensation referee was acting as a quasi-judicial officer and was absolutely immune from liability for his statutorily-assigned tasks); Urbano v. Meneses, 431 A.2d 308 (Pa. Super. 1981) (holding that zoning board members, when ruling on an individual application for a zoning permit, were acting in a quasi-judicial capacity and were entitled to quasi-judicial immunity); Doe v. Wyoming Valley Health Care Sys., Inc., 987 A.2d 758 (Pa. Super. 2009) (concluding that judicial immunity applied to a witness who testified at a National Labor Relations Board employment hearing). As to whether a guardian ad litem is entitled to judicial immunity, for the reasons set forth in the thorough and well-reasoned opinion of Honorable Abbe Fletman of the Court of Common Pleas of Philadelphia County, I would hold that a guardian ad litem is im
" Id. In support of this proposition, we cited to Myers v. Com., Dept. of Labor and Industry, 312 Pa.Super. 61, 458 A.2d 235, 238 (1983) (examining the "nature of the duties" of workmen's compensation referees to determine whether a referee enjoys judicial or quasi-judicial immunity); and Tulio v. Com., State Horse Racing Com'n, 79 Pa.Cmwlth. 305, 470 A.2d 645, 649 (1984) (explaining that "adjudications within an administrative agency share enough of the characteristics of the judicial process (e.g., issuing subpoenas, ruling on evidence, regulating hearings, and making or recommending decisions), that those who participate in them should be absolutely immune from suit for damages. An important element which must be established before this immunity can apply, however, is whether or not the actions complained of were performed within the quasi-judicial function. If not, then quasi-judicial immunity cannot apply."). We also pointed out that a separate bureau within the same state agency performed "adjudicatory functions[,]" featuring the filing and service of legal documents, discovery, presentation of witnesses and evid
In fact, the WCJ has been referred to as "the trial judge of the workers' compensation system". Myers v. Department of Labor and Industry, 458 A.2d 235, 238 (Pa.Super. 1983). Thus, it has long been recognized that the findings of the factfinder in workers' compensation proceedings are as conclusive on appeal as the verdict of a jury, when supported by competent evidence.