Budwin v. American Psychological Association:
a. Doctor-plaintiff served as a neutral expert in a trial custody case. The mom filed a complaint with the American Psychological Association, which censured the doctor.
b. The doctor sued to overturn the censure, making two claims:
(1) litigation privilege protects people who testify in trial from liability.
(a) HELD: the litigation privilege has not been extended to preclude professional disciplinary liability by associations such as the APA.
(2) quasi-judicial immunity bars civil actions for acts performed during trial
(a) HELD: immunity extended to third parties, but does NOT include disciplinary liability by a private association and only speaks to prevent civil suits.
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