California OAH special education order · January 2, 2026
Order of Recusal
OAH Case No. 2025090165 · ALJ Cararea Lucier
ALJ Cararea Lucier recused herself after learning her former law office had advised Parent and attended Student's IEP meetings with Poway in 2017, so a new ALJ will be assigned.
Summary
At a December 29, 2025 prehearing conference, ALJ Lucier disclosed she had a 2017 legal services agreement with Parent. Student's counsel did not object, and Poway reserved the right to object later. Student's counsel then withdrew, and Parent is now self-represented. Further review showed that ALJ Lucier personally gave Parent legal advice in 2017 and that her paralegal attended Student's IEP meetings with Poway, so under Code of Civil Procedure section 170.1 she recused herself to further the interests of justice and to avoid any reasonable doubt about her impartiality.
Why it matters
A judge's earlier work for a family or district can require recusal even when no one objects. Parents and advocates should raise any prior connection between the ALJ and the parties early, because OAH will reassign the case when impartiality could reasonably be questioned.
Key authority cited
- Code Civ. Proc. § 170.1, subd. (a)(6)(A)
People named in the order
- Cararea Lucier, Administrative Law Judge
Topics
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:
PARENT ON BEHALF OF STUDENT,
v.
POWAY UNIFIED SCHOOL DISTRICT.
OAH CASE NUMBER 2025090165
ORDER OF RECUSAL
JANUARY 2, 2026
On December 29, 2025, Administrative Law Judge Cararea Lucier, from the Office of Administrative Hearings, called OAH, convened a prehearing conference in this matter. An Administrative Law Judge is called ALJ. At the prehearing conference ALJ Lucier disclosed she had become aware that morning that she had a legal services agreement with Parent from 2017, although she could not recall any details such as the school district the child attended at the time or whether she met or advised Parent.
Counsel for Student had no objections with ALJ Lucier hearing the case. Counsel for Poway had no immediate objections but reserved the right to object later if his client had concerns.
On December 30, 2025, counsel for Student withdrew on the basis that Parent terminated the legal representation, and stated Parent would proceed with the matter as a self-represented party.
Upon further investigation of past records, ALJ Lucier discovered she met with Parent on October 25, 2017, and provided general legal advice as part of an initial legal consultation. Student attended Poway Unified School District at the time. Parent entered into a legal services agreement with the former law office of ALJ Lucier. A paralegal under the direction of ALJ Lucier attended individualized education program team meetings for Student, convened by Poway Unified School District.
California Code of Civil Procedure section 170.1, subdivision (a)(6)(A) mandates that a judge shall be disqualified if for any reason:
• The judge believes his or her recusal would further the interests of justice.
• The judge believes there is a substantial doubt as to his or her capacity to
be impartial.
• A person aware of the facts might reasonably entertain a doubt that the
judge would be able to be impartial.
ALJ Lucier believes her recusal would further the interests of justice, and that a person aware of the facts might reasonably entertain a doubt of her impartiality.
Accordingly, ALJ Lucier recuses herself from hearing this matter.
OAH will assign a new ALJ to hear the case.
IT IS SO ORDERED.
Cararea Lucier Administrative Law Judge Office of Administrative Hearings