Disqualifying a judge for cause
71 California OAH special education orders on disqualifying a judge for cause, newest first, each with a plain-English summary. Search and filter these orders.
2026
- Order of RecusalALJ Theresa Ravandi recused herself from Student's case against San Marcos Unified, finding recusal would serve the interests of justice and a person aware of the facts might reasonably doubt her impartiality.
- Order of DisqualificationALJ Laurie Gorsline recused herself from the case, finding that recusal would further the interests of justice and that there was substantial doubt about her ability to be impartial.
- Order Denying Challenge for CauseOAH denied Student's challenge for cause against ALJ Paul Kamoroff, finding the record contradicted claims of mistreatment, rushing, and favoritism at the prehearing conference; a second prehearing conference was set to provide counsel's accommodations.
- Order of RecusalALJ 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.
- Order of DisqualificationALJ Laurie Gorsline recused herself because she received information about this case while taking evidence in a separate confidential matter, which counts as ex parte communication in this case.
- Order Denying Peremptory Challenge and Challenge for CauseOAH denied Student's bid to disqualify ALJ Woosley. The peremptory challenge came after he had already held the expedited hearing, and Student showed no actual bias or prejudice.
- Order of DisqualificationALJ 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).
- Order of RecusalALJ Claire Yazigi recused herself on her own motion after finding she had mediated a separate case between the same parties on the same issue, because mediation discussions are confidential.
- Order Denying Student's Renewed Challenge for CauseOAH 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.
- Order Denying Student's Challenge for CauseOAH denied Student's challenge to disqualify ALJ Kara Hatfield for cause, finding Student misreported her remarks about her caseload and that unhappiness with the pace and outcome of rulings does not show bias.
- Order of RecusalALJ 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.
2025
- Order Denying Disqualification of Administrative Law JudgeOAH denied Parent's mid-hearing motion to disqualify the ALJ for bias, finding that rulings on objections, evidence, question scope, and disability accommodations were within the ALJ's authority and showed no actual bias.
- Order Denying Student's Second ALJ Challenge for CauseOAH denied Student's second challenge for cause against ALJ Pahl, finding no factual showing of actual bias and treating the complaints as disagreements with rulings and procedural requirements that apply equally to both sides.
- Order Denying Student's Administrative Law Judge Challenge for CauseOAH denied Student's challenge for cause against ALJ Pahl because Student showed no facts of actual bias. Prior rulings, a prior case, and two fixable hearing errors are not grounds for disqualification.
- Order Denying Student's Administrative Law Judge Challenge for CauseOAH denied Student's challenge for cause against ALJ Pahl because Student showed no facts of actual bias, and prior rulings and fixed hearing errors in an earlier case do not prove bias.
- Order of DisqualificationALJ Kara Hatfield recused herself from the case on her own motion, finding that recusal would further the interests of justice and that her impartiality could reasonably be doubted.
- Order Denying Challenge for Cause and Request for RecusalOAH denied Student's request to remove ALJ Ted Mann. A peremptory challenge was untimely after the prehearing conference, and disagreement with his consolidation and continuance rulings did not show actual bias.
- Order of DisqualificationALJ Cynthia Fritz recused herself from the due process hearing because she regularly works with Pacifica's counsel in a State Bar group that counsel chairs, which could raise doubts about her impartiality.
- Order Denying Challenge for CauseOAH denied Parent's renewed motion to disqualify ALJ Dan Senter because Parent showed no facts of actual bias, repeated arguments already rejected, and the record showed the ALJ helped her get disability accommodations.
- Order Denying Challenge for CauseALJ denied Parent's challenge for cause because a three-month 2009 law clerkship at the district's law firm and alleged hearing-date mix-ups at the prehearing conference did not show actual bias.
- Order of DisqualificationALJ Kara Hatfield recused herself from Student's case against Los Angeles Unified because she found her recusal would further the interests of justice and her impartiality could reasonably be doubted.
- Order of RecusalALJ Paul H. Kamoroff recused himself from the consolidated San Dieguito cases, finding recusal would serve the interests of justice and a person aware of the facts might reasonably doubt his impartiality.
- Order Denying Request to Remove Administrative Law JudgeOAH denied Del Norte's mid-hearing request to remove the ALJ because the district showed no actual bias, and any peremptory challenge came too late after the hearing began.
2024
- Order of RecusalALJ Paul H. Kamoroff recused himself from Student's case against Laguna Beach Unified, finding recusal would further the interests of justice and a reasonable person might doubt his impartiality.
- Order Denying Motion to Disqualify Administrative Law JudgeOAH denied Monrovia's mid-hearing motion to disqualify the ALJ, holding that an AI scan showing 68.3 percent of objection rulings favored Student does not prove actual bias.
- Order Denying Challenge for CauseOAH denied Father's mid-hearing request to remove ALJ Dalton. Remarks the judge made while ruling on Father's continuance request did not show actual bias, prejudice, or interest in the case.
- Amended, Corrected and Supplemental Order Denying Challenge for Cause and Denying Motion Regarding Revision of IssuesOAH denied Parent's mid-hearing challenge for cause against the ALJ because disagreement with the ALJ's rulings is not bias, and it overruled Parent's late objections to how the hearing issues were restated.
- Order Denying Challenge for CauseOAH denied Parent's mid-hearing challenge for cause against ALJ Gorsline because disagreeing with the judge's rulings on continuance, amendment, exhibits, and issue clarification does not show actual bias or a conflict of interest.
- Order Denying Request for Reconsideration; Order Denying Challenge for CauseOAH denied Parent's request to reconsider the denial of a challenge for cause against Division Chief ALJ Castillo because Parent repeated the same unsupported bias claims and offered no new facts or law.
- Order Denying Challenge for CauseOAH denied Parent's challenge for cause against Division Chief ALJ Castillo. Parent's claims of a conspiracy with the District's law firm were speculation, and adverse rulings alone do not show bias.
- Order of DisqualificationALJ Kara Hatfield recused herself from Student's case against Los Angeles Unified, finding recusal would serve justice and that her impartiality could reasonably be doubted.
- Order of DisqualificationALJ Kara Hatfield recused herself from the case on her own motion. She found that recusal would further the interests of justice and that a reasonable person might doubt her impartiality.
- Order of DisqualificationALJ Kara Hatfield recused herself from the prehearing conference and the case, finding that recusal would further the interests of justice and that her impartiality could reasonably be doubted.
- Order of RecusalALJ Paul Kamoroff recused himself from the due process hearing, finding recusal would further the interests of justice and a person aware of the facts might reasonably doubt his impartiality.
- Order of RecusalALJ Paul Kamoroff recused himself from the due process hearing. He found that recusal would further the interests of justice and that a person aware of the facts might reasonably doubt his impartiality.
- Order Following Prehearing Conference and Recusal of Administrative Law JudgeALJ Tiffany Gilmartin recused herself after learning at the prehearing conference that she and Student's father served in the same military unit as recently as 2023.
- Order Notifying Parties of Possible Receipt of Attorney-Client Communications, Continuance of Prehearing Conference and Due Process Hearing, and Recusal of Administrative Law JudgeALJ recused herself and continued the hearing after Downey filed a due process complaint containing internal comments between Downey and its counsel; Downey must refile a clean version.
- Order of DisqualificationALJ Laurie Gorsline recused herself from the case. She found that recusal would further the interests of justice and that there was substantial doubt about her ability to be impartial.
- Order Denying Challenge for CauseOAH denied Parent's mid-hearing challenge for cause against ALJ Charles Marson because a series of adverse rulings, including cutting off an unproductive cross-examination, does not show actual bias.
2023
- Order of Disqualification Pursuant to California Code of Civil Procedure Section 170.1ALJ Sabrina Kong recused herself from the case under Code of Civil Procedure section 170.1(a)(6), citing the interests of justice and possible doubts about impartiality.
- Order Granting Request for Reconsideration but Confirming RulingOAH granted reconsideration but again refused to reassign the ALJ who had mediated Student's earlier case, because his promise not to hear that case did not cover new cases and he remembered nothing about it.
- Order Following Prehearing Conference for Hearing by Videoconference Denying Challenge for Cause, Motion to Consolidate, and Request for ContinuanceOAH denied Student's challenge for cause, motion to consolidate, and continuance request. The ALJ did not remember mediating a prior case, and the other two motions were untimely and unsupported.
- Order Following Prehearing Conference, Granting Request for Continuance, Denying Motion to Disqualify the Administrative Law Judge for CauseOAH denied Parent's oral motion to disqualify the ALJ for cause because Parent gave no factual basis for recusal, and granted Student's continuance so the parties could mediate.
- Order Denying Charter's Challenge to ALJ ArdenOAH denied Granite Charter's challenge to ALJ Arden. The peremptory challenge was filed after the prehearing conference, and disagreeing with her sua sponte dismissal of issues is not proof of bias.
2021
2020
- Order Denying Challenge for CauseOAH denied Empire Springs Charter School's challenge for cause against ALJ Cararea Lucier, finding that her past cases as an attorney against a different charter school in the same network did not show actual bias.
- Order Granting Request for Recusal and Vacating Order Regarding Statute of LimitationsALJ recused himself because he had mediated an earlier case between the same parties involving some of the same issues, and vacated his statute of limitations ruling, though Student showed no actual bias.
2019
- Order Denying Challenge for CauseOAH denied Student's challenge for cause to disqualify ALJ Cole Dalton, finding that unfavorable prior rulings and the ALJ's choice not to reprimand district counsel do not show actual bias.
- Order Granting Motion to Exclude Confidential Communications; Order Requiring Student to Refrain From Filing Evidence Intended to Be Used at Hearing; and Order of DisqualificationOAH locked away three Student filings that disclosed confidential mediation and settlement communications, and the ALJ disqualified herself from the hearing because she had read them.
- Order Denying Challenge for CauseOAH denied Student's motion to disqualify ALJ Hohensee for cause because claims of erroneous rulings, retaliation, and her knowledge of Parent's complaint letter did not show actual bias.
2018
- Order Granting Challenge for CauseALJ Cole Dalton granted Student's challenge for cause and stepped aside because she had mediated an earlier dispute between the same parties, and could recall confidential mediation information during the hearing.
- Order Granting Request for Reconsideration, Denying Motion for Continuance to File Second Amended Complaint, and Denying Challenge for CauseOAH denied Student's challenge for cause against the ALJ because no actual bias was shown, and on reconsideration again refused to continue the hearing so Student could file a second amended complaint.
- Order Denying Challenge for CauseOAH denied Student's challenge to disqualify ALJ Charles Marson, finding that disagreement with his rulings in an earlier case, including a final decision against Student, does not show actual bias.
2017
- Order Denying Challenge for CauseOAH denied Student's challenge for cause against ALJ Penelope Pahl because explaining hearing procedures and urging early planning for a child witness's accommodations is part of an ALJ's job, not evidence of bias.
- Order Denying Challenge for CauseOAH denied Parent's challenge to disqualify ALJ Tara Doss because disagreeing with her prehearing conference rulings, including rewording District's issue, is not a factual showing of actual bias.
- Order Denying Challenge for CauseOAH denied Kern's challenge for cause against ALJ Rita Defilippis because her prior work representing students against the same law firm in an unrelated case did not show actual bias.
2016
- Notice of Disqualifying Disclosure and Order of RecusalALJ recused herself mid-hearing after learning from exhibits that Student had been represented by Disability Rights California, her husband's employer, during the period at issue in the case.
- Order Following Prehearing Conference, Denying Student's Peremptory Challenge, Denying Student's Motion to Challenge the ALJ for Cause, Granting in Part Student's Motion to Allow Telephonic Testimony, Denying Student's Motion to Allow Video Recording in Hearing Room, and Granting Motion to Allow Media in Hearing Room Subject to ConditionOAH denied Student's challenges to the ALJ because Student had already used his one peremptory challenge, and late notice of reassignment and prior prehearing rulings do not show bias or prejudice.
- Order Denying Challenge for CauseALJ Alexa Hohensee denied Student's challenge for cause because her work at District's law firm, Lozano Smith, in 2002-2003 was too remote to show actual bias, prejudice, or interest.
- Notice of Administrative Law Judge Disqualification and Order Assigning New Administrative Law JudgeThe hearing judge disqualified herself mid-hearing after the district's SELPA director sent OAH an improper ex parte communication, and OAH reassigned the case to a new judge.
2015
- Order Denying Challenge for CauseOAH denied Sacramento's verbal request that the ALJ recuse herself over a past job alongside Student's attorney, because the District showed no facts of actual bias or prejudice.
- Order Denying Challenge to Administrative Law JudgeOAH denied Parents' bid to disqualify ALJ Marian Tully for discrimination, finding that complaints about her hearing management, witness questioning, time limits, and evidentiary rulings fall within ALJ discretion and show no actual bias.
- Order Denying Challenge for CauseOAH denied Student's challenge for cause against ALJ Judith Pasewark, finding her participation in a public special education panel months before the case was filed showed no actual bias.
- Order of Nonaction Without PrejudiceOAH took no action on Student's letter asking that a different ALJ review all rulings, because it was unclear whether Student sought reconsideration, disqualification for cause, or a peremptory challenge.
- Order Following Prehearing Conference; Denying Peremptory Challenge and Challenge for Cause; and Continuing First Day of HearingOAH denied Student's peremptory challenge as untimely because the hearing had already begun with the January expedited hearing, and denied the challenge for cause because no actual bias was shown.
2014
- Order Granting Challenge for CauseALJ Charles Marson granted Student's challenge for cause against himself because he had mediated an earlier due process matter involving Student and learned confidential information about her.
- Order Following Prehearing ConferenceOAH denied Cupertino's motion to remove the ALJ for cause. Her earlier decision between the same parties being on federal appeal is not cause for removal. The order also set the hearing's issues and procedures.
2013
- Order Denying Challenge for CauseOAH denied Student's challenge for cause against ALJ Deidre L. Johnson because unhappiness with her adverse prehearing rulings, including denial of a third continuance, does not show actual bias.
- Order Denying Challenge for CauseOAH denied Student's challenge for cause against ALJ Charles Marson because disagreement with how the prehearing conference order framed a hearing issue is a ruling, not proof of bias.
- Order Denying Challenge for CauseOAH denied Student's challenge to disqualify ALJ Margaret M. Broussard because Student showed no actual bias; the ALJ's brief employment with Student's attorney over ten years earlier was not enough.
- Order Following Pre-Hearing ConferenceOAH denied the District's motion to disqualify the ALJ, who had mediated Student's earlier case against other districts, because the District showed no actual bias. OAH granted the District a five-week continuance.