Obos

This lawsuit raises the issue of the application of judicial privilege to communications regarding a third party, made in the course of a court-ordered child custody and placement investigation in connection with a child custody dispute. In the course of such an investigation, a court-appointed psychologist was told the mother’s boyfriend, Steven J. Obos, had been dishonorably discharged from the military and fired from his job for dishonesty. The psychologist discussed these allegations with the children’s attorney and with their therapist. Obos then filed this action for defamation and invasion of privacy, asserting the communications with the children’s attorney and therapist damaged his reputation, and contending the judicial privilege did not apply to these communications because Obos was not a party to the underlying action. The trial court granted defendants’ motion for summary judgment, finding the communications were privileged. Obos appeals; we affirm.

Factual and Procedural Background

As Obos acknowledged in the underlying summary judgment proceedings, the following facts are undisputed: In 1993, Connie Sifers was involved in a dissolution/child custody…