California OAH special education order · February 4, 2026
Order Denying Student's Renewed Challenge for Cause
OAH Case No. 2025110210, 2025110972 · ALJ Kara Hatfield
OAH denied Student's renewed challenge for cause against ALJ Kara Hatfield because the challenged judge is the one who decides the challenge under law, and the new grounds repeated the original ones.
This case went to decision
Student v. Cupertino Union School District: Cupertino Union wins expedited case: no disciplinary removals proven, so no manifestation determination was required. (2026)
Summary
Student's first challenge for cause seeking to disqualify ALJ Kara Hatfield was denied on February 2, 2026. Student then filed a renewed challenge, arguing the first one was improperly decided by the challenged judge herself. ALJ Hatfield denied the renewed challenge. She explained that under Code of Civil Procedure section 170.3 the challenged judge decides whether she is disqualified, and that Student's added grounds repeated those already rejected. All previously set dates were confirmed.
Why it matters
In OAH special education cases, the judge being challenged rules on the challenge for cause. Simply refiling the same grounds will not get a different result, and it does not pause the hearing schedule.
Key authority cited
- Code Civ. Proc., § 170.3
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 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 RENEWED
CHALLENGE FOR CAUSE
FEBRUARY 4, 2026
On January 30, 2026, Student filed a challenge for cause seeking to disqualify Administrative Law Judge Kara Hatfield from hearing this case. On February 2, 2026, the Office of Administrative Hearings issued an Order Denying Student’s Challenge for Cause.
On February 3, 2026, Student filed a “Renewed Challenge of ALJ for Cause”
alleging his prior challenge for cause was improperly ruled upon by the challenged Administrative Law Judge.
Student’s “Renewed Motion to Disqualify ALJ for Cause” is premised on Student’s incorrect belief that anyone other than the challenged Administrative Law Judge is supposed to rule on a challenge for cause. The challenged judge is by law the person who determines if the challenged judge is disqualified. (Code Civ. Proc., § 170.3.)
Student’s addition grounds for renewing his challenge for cause are repetitive of the grounds stated in his original challenge for cause. For the same reasons stated in the February 2, 2026, Order Denying Student’s Challenge for Cause, Student’s Renewed Motion to Disqualify ALJ for Cause is denied.
ORDER
Student’s renewed 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