California OAH special education order · April 28, 2025

Order Denying District's Peremptory Challenge

OAH Case No. 2025040010 · ALJ Tara Doss

OAH denied Mendocino's peremptory challenge to ALJ Paul Kamoroff because the District had already used its one allowed peremptory challenge against ALJ Theresa Ravandi earlier in the case.

Denied Peremptory challenges

This case went to decision

Mendocino Unified School District v. Student: Mendocino Unified must fund an independent speech and language evaluation after failing to prove its triennial assessment was appropriate. (2025)

Summary

Mendocino Unified School District filed a peremptory challenge seeking to disqualify ALJ Paul Kamoroff without cause. OAH denied it. On April 7, 2025, OAH had already granted the District's peremptory challenge to ALJ Theresa Ravandi, and a party gets only one peremptory challenge per case. The case will go forward as scheduled before ALJ Kamoroff.

Why it matters

Each party gets only one no-reason challenge to an assigned judge per case. After it is used, any later attempt to remove a judge must show actual cause.

Key authority cited

  • Gov. Code, § 11425.40, subd. (d)
  • Cal. Code Regs., tit. 1, § 1034, subds. (a) & (b)

People named in the order

  • Paul Kamoroff, Administrative Law Judge (challenged)
  • Theresa Ravandi, Administrative Law Judge (previously challenged)
  • Tara Doss, Presiding Administrative Law Judge

Topics

peremptory challenge alj disqualification one challenge limit district motion

Full text of the order

Published text of the OAH order. Page headers and numbers from the original PDF have been dropped.

BEFORE THE

OFFICE OF ADMINISTRATIVE HEARINGS

STATE OF CALIFORNIA

IN THE MATTER OF:

MENDOCINO UNIFIED SCHOOL DISTRICT,

v.

PARENTS ON BEHALF OF STUDENT.

OAH CASE NUMBER 2025040010

ORDER DENYING DISTRICT’S PEREMPTORY CHALLENGE

APRIL 28, 2025

On April 28, 2025, Mendocino Unified School District filed a notice of peremptory challenge with the Office of Administrative Hearings, called OAH, to Administrative Law Judge Paul Kamoroff. An Administrative Law Judge is called ALJ. Mendocino’s peremptory challenge is made pursuant to Government Code section 11425.40, subdivision (d), of the Administrative Procedures Act, and California Code of Regulations, title 1, section 1034.

Government Code section 11425.40, subdivision (d), establishes the criteria for disqualification of the presiding officer. A party is entitled to one peremptory challenge, also called disqualification without cause, to an ALJ assigned to an OAH hearing. (Cal.

Code Regs., tit. 1, § 1034, subds. (a) & (b); Gov. Code, § 11425.40, subd. (d).)

Mendocino’s peremptory challenge is denied pursuant to Government Code section 11425.40, subdivision (d), and California Code of Regulations, title 1, section 1034, subdivisions (a) and (b). On April 7, 2025, OAH granted Mendocino’s peremptory challenge of ALJ Theresa Ravandi. Mendocino is only entitled to one peremptory challenge in this case. The case will proceed as scheduled with ALJ Paul Kamoroff.

IT IS SO ORDERED.

Tara Doss Presiding Administrative Law Judge Office of Administrative Hearings