California Case Summaries

Bombardini v. Board of Psychology — Challenge to Discipline Was Untimely and Probation Ruling Stands

Reported / Citable

Case
Bombardini v. Board of Psychology
Court
3rd District Court of Appeal
Judge
Laurie Earl (Gavin Newsom, 2021)
Date Decided
2026-10-06
Docket No.
C104172
Status
Reported / Citable
Topics
professional licensing, psychologist discipline, administrative mandate, limitations period

Background

The California Board of Psychology placed licensed psychologist Morella Bombardini on five years of probation in 2021. In 2024 the Board denied her request to terminate probation early.

Bombardini used a mandate petition to attack both the original discipline and the later refusal to end probation. The superior court found the first challenge untimely and upheld the second on the administrative record.

The Court’s Holding

The Third District affirmed. A later petition concerning early termination did not reopen the expired time to seek judicial review of the 2021 disciplinary decision.

The Board had evidentiary support and discretion to conclude that continued probation served public protection. Bombardini’s complaints about notice, evidence, and a remote hearing did not establish prejudicial unfairness, particularly without an adequate hearing transcript.

Key Takeaways

  • Licensees must calendar the review deadline from the original disciplinary decision.
  • A petition to modify or end probation does not revive a stale challenge to the underlying discipline.
  • An appellant must supply a record adequate to demonstrate claimed hearing error.
  • Public protection is the Board of Psychology’s highest statutory priority.

Why It Matters

The opinion is a caution for California licensed professionals: preserving review of the initial discipline and seeking later modification are separate tasks. Counsel should file timely mandate proceedings and ensure the record includes transcripts and exhibits needed to prove procedural prejudice.

Read the full opinion (PDF) · Court docket

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