California OAH special education order · April 3, 2026
Order of Disqualification
OAH Case No. 2025111012 · ALJ Sabrina Kong
ALJ Sabrina Kong recused herself from Student's case against Pasadena Unified a day after assignment, citing the interests of justice and possible doubts about impartiality under Code of Civil Procedure section 170.1(a)(6).
Summary
ALJ Sabrina Kong was assigned this case on April 2, 2026. The next day she disqualified herself on her own initiative under Code of Civil Procedure section 170.1(a)(6)(A). That section requires recusal when the judge believes it would further the interests of justice, when the judge has substantial doubt about her own impartiality, or when a person aware of the facts might reasonably doubt her impartiality. The order gives no specific facts behind the recusal.
Why it matters
ALJs may step aside on their own when impartiality could be questioned, without any party asking. A self-recusal does not use up a party's peremptory challenge, and the case will be reassigned to a new ALJ.
Key authority cited
- Cal. Code Civ. Proc. § 170.1(a)(6)(A)
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.
PASADENA UNIFIED SCHOOL DISTRICT.
OAH CASE NUMBER 2025111012
ORDER OF DISQUALIFICATION
APRIL 3, 2026
On April 2, 2026, Administrative Law Judge Sabrina Kong was assigned this case.
Administrative Law Judge is called an ALJ. ALJ Kong hereby recuses herself for all reasons under California Code of Civil Procedure Section 170.1(a)(6) which states that a judge shall be disqualified:
“(A) For any reason:
(i) The judge believes his or her recusal would further the interests of justice.
(ii) The judge believes there is a substantial doubt as to his or her capacity to be impartial.
(iii) A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial.”
(Cal. Code Civ. Proc. § 170.1(a)(6)(A)(i)(ii) and (iii).)
IT IS SO ORDERED.
Sabrina Kong Administrative Law Judge Office of Administrative Hearings