Order Denying Student's Challenge for Cause

BEFORE THE

OFFICE OF ADMINISTRATIVE HEARINGS

STATE OF CALIFORNIA

IN THE CONSOLIDATED MATTERS INVOLVING:

PARENT ON BEHALF OF STUDENT,

and

CUPERTINO UNION SCHOOL DISTRICT,

OAH CASE NUMBER 2025110210

OAH CASE NUMBER 2025110972

ORDER DENYING STUDENT’S CHALLENGE FOR CAUSE

FEBRUARY 2, 2026

On January 30, 2026, Student filed a challenge for cause seeking to disqualify Administrative Law Judge Kara Hatfield from hearing this case.

An Administrative Law Judge may be disqualified for bias, prejudice, or interest in the proceeding. (Gov. Code, § 11425.40, subd. (a).) The following, without further evidence of bias, prejudice, or interest, are not by themselves grounds for disqualification:

• The Administrative Law Judge is or is not a member of a racial, ethnic,

religious, sexual, or similar group and the proceeding involves the rights of that group;

• The Administrative Law Judge has experience, technical competence, or

specialized knowledge of, or has in any capacity expressed a view on, a legal, factual, or policy issue presented in the proceeding; or

• The Administrative Law Judge has as a lawyer or public official participated

in the drafting of laws or regulations or in the effort to pass or defeat laws or regulations, the meaning, effect, or application of which is in issue in the proceeding. (Gov. Code, § 11425.40, subd. (b).)

In other words, to disqualify an Administrative Law Judge for cause, a factual showing of actual bias or prejudice is required. (See American Isuzu Motors, Inc. v. New Motor Vehicle Board (1986) 186 Cal.App.3d 464, 472.) For example, to be a basis for disqualification, the financial interest of the Administrative Law Judge in the outcome of the case must be direct, personal, and substantial, rather than slight. (Haas v. County of San Bernardino (2002) 27 Cal.4th 1017, 1031.) Personal involvement in the case by the Administrative Law Judge or familial connections may warrant disqualification based solely on the probability of bias. (See Clark v. City of Hermosa Beach (1996) 48 Cal.App.4th 1152, 1170-1173.) However, in most other cases, including claims of bias arising from the hearing officer’s personal or political views, disqualification will not occur absent a showing of actual bias. (Haas, supra, 27 Cal.4th at p. 1032.)

Student asserts Administrative Law Judge Hatfield has failed to exercise discretion, demonstrated bias against Student and favoritism toward Cupertino Union School District, and prematurely advanced the expedited due process hearing toward decision while due process violations remain uncured. Student alleges, specifically, Administrative Law Judge Hatfield “repeatedly made remarks during this proceeding that she is presiding over many other cases in addition to this instant case, affecting her ability to impartially render her responsibilities.”

Student falsely reports the statement by Administrative Law Judge Hatfield.

Administrative Law Judge Hatfield never said or suggested any of her work responsibilities prevented her from being impartial. Student’s false accusation is belied by the record of the expedited due process hearing on January 14, 2026. Administrative Law Judge Hatfield responded to Parent’s inquiry about when certain pending written motions Parent believed were ripe for ruling would be ruled upon by informing the parties the Administrative Law Judge was not exclusively working on this case and was conducting the research Student’s motions requested: “[M]aybe you think that this is the only thing that I am required to work on and that is not the situation. I am responsible for many cases and I do not have exclusive time for this case. So, I am taking care of things as I can. ‘Ripe for ruling’ means there is nothing more for the parties to do; it is my turn to work on them. Many of your motions include citations to other OAH cases that you want me to look at. Doing research takes time. I am following the leads that you have laid out and I cannot immediately answer all of your motions. I'm working on things.”

Student has failed to make the showing necessary to disqualify Administrative Law Judge Hatfield for cause. Student’s challenge to the Administrative Law Judge “for cause” based on Parent’s dissatisfaction with the pace and outcome of rulings related to the expedited due process hearing is insufficient to demonstrate prejudice or a conflict of interest.

ORDER

Student’s motion challenging Administrative Law Judge Hatfield for cause and seeking to disqualify Administrative Law Judge Hatfield from issuing rulings on pending motions, issuing a decision on Student’s expedited claims, and continuing hearing this case is denied. All dates previously set in this matter are confirmed.

Kara Hatfield Administrative Law Judge Office of Administrative Hearings