California OAH special education order · July 8, 2026
Order of Recusal
OAH Case No. 2026040407, 2026020114 · ALJ Paul H. Kamoroff
ALJ Paul H. Kamoroff recused himself from the consolidated Huntington Beach hearing. He found that recusal would further the interests of justice and that a person aware of the facts might reasonably doubt his impartiality.
Summary
OAH reassigned this consolidated case to ALJ Paul H. Kamoroff on July 8, 2026, after ALJ Sabrina Kong, who held the prehearing conference, became unavailable. That same day, on his own initiative, ALJ Kamoroff recused himself under Code of Civil Procedure section 170.1, subdivision (a)(6)(A). He found that recusal would further the interests of justice and that a person aware of the facts might reasonably doubt his impartiality. The order does not say what facts led to the recusal.
Why it matters
An ALJ can step aside on their own, without any party filing a motion, when impartiality could reasonably be questioned. When that happens, the hearing must be reassigned to another judge, which may affect scheduling.
Key authority cited
- Code Civ. Proc., § 170.1, subd. (a)(6)(A)
People named in the order
- Sabrina Kong, Administrative Law Judge who conducted the prehearing conference
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 OF:
PARENTS ON BEHALF OF STUDENT,
v.
HUNTINGTON BEACH CITY SCHOOL DISTRICT.
OAH CASE NUMBER 2026040407
OAH CASE NUMBER 2026020114
ORDER OF RECUSAL
JULY 8, 2026
On February 2, 2026, Huntington Beach City School District, called Huntington Beach, filed with the Office of Administrative Hearings, called OAH, a Request for Due Process hearing in OAH case number 2026020114, naming Student. On April 7, 2026, Student filed a Request for Due Process Hearing in OAH case number 2026040407, naming Huntington Beach.
On April 17, 2026, OAH granted Student’s request to consolidate the cases. On July 6, 2026, ALJ Sabrina Kong conducted the prehearing conference. On July 8, 2026, OAH assigned Administrative Law Judge Paul H. Kamoroff to the due process hearing for the consolidated matter after ALJ Kong became unavailable for hearing. The Administrative Law Judge is called an ALJ.
California Code of Civil Procedure section 170.1, subdivision (a)(6)(A) mandates that a judge shall be disqualified if 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.
ALJ Kamoroff believes that his recusal would further the interests of justice and a person aware of the facts might reasonably entertain a doubt that ALJ Kamoroff would be able to be impartial. Accordingly, ALJ Kamoroff recuses himself from hearing this matter.
IT IS SO ORDERED.
Paul H Kamoroff Administrative Law Judge Office of Administrative Hearings