Gould v. Director, New Hampshire Division of Motor Vehicles

The director of the New Hampshire Division of Motor Vehicles appeals the decision of the Superior Court (McHugh, J.) awarding the plaintiff, Erin P. Gould, attorney’s fees for her appeal from a default judgment entered against her by the division and for her pre-appeal efforts to have the default vacated by the division. The defendant argues that the award of attorney’s fees based upon actions taken by a State official acting in his quasi-judicial capacity violates both the doctrines of sovereign immunity and of quasi-judicial immunity. Because we reverse on the basis of quasi-judicial…