"Over the years, the Barton Doctrine was expanded beyond receiverships to include bankruptcy trustees, as they are the statutory successors to the equity receiver.
It is well recognized that bankruptcy trustees are officers of the appointing court and are entitled to quasi-judicial immunity. The lengthy subject of immunity is beyond the scope of this article.
However, a good discussion can be found at In re Castillo, 297 F.3d 940 (9th Cir. 2002)."
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