CCPCIVILRGHTS, 7:8. State action test, Cal. Civ. Prac.

Civil Rights Litigation 7:8

Cal. Civ. Prac. Civil Rights Litigation 7:8

California Civil Practice Civil Rights Litigation
Database updated October 2012
Judge Harold E. Kahn and Robert D. Links, Esq.
Chapter 7. Due Process of Law
III. The Elements of a Due Process Claim
Summary
7:8. State action test
The issue of what constitutes state action has been the subject of vigorous litigation. [See, for example, Moose Lodge No.
107 v. Irvis, 407 U.S. 163, 92 S. Ct. 1965, 32 L. Ed. 2d 627 (1972); Adams v. Department of Motor Vehicles, 11 Cal. 3d 146,
113 Cal. Rptr. 145, 520 P.2d 961, 64 A.L.R.3d 803 (1974) and numerous law review articles. See, e.g., The State Action
Doctrine and the Rehnquist Court, 25 Hast Const LQ 588 (1991)] For years, commentators have struggled to find consistency
in the decisions defining state action for constitutional purposes. One commentator has labeled the courts treatment of the
issue a conceptual disaster area. [See The Supreme Court, 1966 TermForward: State Action, Equal Protection and
Californias Proposition 14, 81 Harv L. Rev. 69 (1967)]
While the many state and federal decisions dealing with the concept of state action are difficult to reconcile, they have
established several broad principles that help determine when a given act amounts to state action.
To begin with, there must be a significant level of state involvement. [See Garfinkle v. Superior Court, 21 Cal. 3d 268, 146
Cal. Rptr. 208, 578 P.2d 925 (1978); Kruger v. Wells Fargo Bank, 11 Cal. 3d 352, 113 Cal. Rptr. 449, 521 P.2d 441, 65
A.L.R.3d 1266 (1974)]
Often, state action consists of legislative action, such as the passage of statutes or regulations that improperly deprive people
of life, liberty, or property without adequate procedural safeguards. [See, for example, Randone v. Appellate Department, 5
Cal. 3d 536, 96 Cal. Rptr. 709, 488 P.2d 13 (1971) (attachment statute ruled unconstitutional on procedural grounds)]
However, state action can also consist of executive and judicial action. [Adams v. Department of Motor Vehicles, 11 Cal. 3d
146, 113 Cal. Rptr. 145, 520 P.2d 961, 64 A.L.R.3d 803 (1974)]
Therefore, a key ingredient in finding state action is that the government must be a joint participant in the challenged
conduct, even if only by way of ministerial actions. For example, the United States Supreme Court found state action present
in a private, racially restrictive real estate covenant, because the covenant could not be enforced without the involvement of
the Illinois courts. [Shelley v. Kraemer, 334 U.S. 1, 68 S. Ct. 836, 92 L. Ed. 1161, 3 A.L.R.2d 441 (1948)]
The contrary situation, where action can be taken solely by private parties without governmental assistance, yields the
opposite result. Hence, the California Supreme Court refused to find state action in a case involving a private banks setoff of
charge account debts against a depositors checking account. The court held that, in contrast to other prejudgment remedies,
the banks setoff procedure required no act of assistance from state officials, and thus did not violate the federal and state Due
Process Clauses. [Kruger v. Wells Fargo Bank, 11 Cal. 3d 352, 113 Cal. Rptr. 449, 521 P.2d 441, 65 A.L.R.3d 1266 (1974)]
The governments participation does not have to be direct or all-encompassing in order to constitute state action for due
process purposes. In a given case, private conduct may become so entwined with governmental action that it becomes subject
to the constitutional limitations of due process. [See, e.g., Reitman v. Mulkey, 387 U.S. 369, 87 S. Ct. 1627, 18 L. Ed. 2d 830
(1967); Adams v. Department of Motor Vehicles, 11 Cal. 3d 146, 113 Cal. Rptr. 145, 520 P.2d 961, 64 A.L.R.3d 803 (1974)]
The question in these cases is whether there is a sufficiently close nexus between the state and the challenged action so that
2012 Thomson Reuters. No claim to original U.S. Government Works.

CCPCIVILRGHTS, 7:8. State action test, Cal. Civ. Prac. Civil Rights Litigation 7:8

the action may be fairly treated as that of the state itself. [Garfinkle v. Superior Court, 21 Cal. 3d 268, 146 Cal. Rptr. 208, 578
P.2d 925 (1978); see also Jackson v. Metropolitan Edison Co., 419 U.S. 345, 95 S. Ct. 449, 42 L. Ed. 2d 477, 8 Pub. Util.
Rep. 4th (PUR) 1 (1974)]
Often, this question turns on whether the state has encouraged or actively participated in the challenged conduct. Mere
recognition by the state of private relationships does not meet the test. Nor does the fact that state action facilitates a private
partys conduct. The state must be an integral participant in the conduct. [Garfinkle v. Superior Court, 21 Cal. 3d 268, 146
Cal. Rptr. 208, 578 P.2d 925 (1978)]
Thus, for example, though the government may license certain conduct, such as the serving of liquor, it does not necessarily
follow that state action occurs as the result of the licensees activities. [See, for example, Moose Lodge No. 107 v. Irvis, 407
U.S. 163, 92 S. Ct. 1965, 32 L. Ed. 2d 627 (1972)] It is important to remember that even where a large, institutional
organization exerts substantial control over an important enterprise, there may not be state action. [See, for example, National
Collegiate Athletic Assn v. Tarkanian, 488 U.S. 179, 109 S. Ct. 454, 102 L. Ed. 2d 469, 50 Ed. Law Rep. 17 (1988) (acts of
NCAA, which controls college athletics in United States, did not amount to state action); see also San Francisco Arts &
Athletics, Inc. v. U.S. Olympic Committee, 483 U.S. 522, 107 S. Ct. 2971, 97 L. Ed. 2d 427, 3 U.S.P.Q.2d (BNA) 1145
(1987) (actions of United States Olympic Committee, a federally chartered nonprofit corporation, did not constitute state
action)]
In a case challenging Californias procedure for nonjudicial foreclosures of deeds of trust on real property, the California
Supreme Court found that the procedure constituted private action exempt from the due process constraints of the federal and
state constitutions. The court concluded that mere recognition of the legal effect of private arrangements between a lender
and trustor is not sufficient to convert the acts of the lender or trustee into state action for Fourteenth Amendment purposes.
The court also discounted the argument that the state encouraged nonjudicial foreclosure by acknowledging the legal validity
of the title transferred thereby. [Garfinkle v. Superior Court, 21 Cal. 3d 268, 146 Cal. Rptr. 208, 578 P.2d 925 (1978)]
Practice Note:
At first glance, Garfinkle appears difficult to distinguish from Shelley v. Kraemer, 334 U.S. 1, 68 S. Ct. 836, 92 L. Ed. 1161,
3 A.L.R.2d 441 (1948), in which the United State Supreme Court found state action in an equal protection context where
there was solely private conduct, in the form of a restrictive covenant contained in a private sale agreement involving
residential real estate. The only state action in Shelley was judicial enforcement of the parties contract, something virtually
identical to the nonjudicial foreclosure at issue in Garfinkle. The two cases are distinguishable, however, in that Shelley
involved the states participation in racial discrimination, something prohibited by the equal protection clause, while
Garfinkle involved private foreclosures that did not involve any other constitutional right. This may also explain why the
Garfinkle court did not cite Shelley in its state action analysis.
Generally speaking, the California Supreme Court has utilized the federal standard in deciding whether there is state action
for purposes of the California Due Process Clause. [See Garfinkle v. Superior Court, 21 Cal. 3d 268, 146 Cal. Rptr. 208, 578
P.2d 925 (1978); Kruger v. Wells Fargo Bank, 11 Cal. 3d 352, 113 Cal. Rptr. 449, 521 P.2d 441, 65 A.L.R.3d 1266 (1974)
(implying state action requirement into California Due Process Clause, then following federal case law)]
Practice Tips:
The U.S. Supreme Court has enumerated at least seven approaches to determine if a private partys conduct amounts to state
action. The approaches were summarized in Brentwood Academy v. Tennessee Secondary School Athletic Assn, 531 U.S.
288, 296, 121 S. Ct. 924, 148 L. Ed. 2d 807, 151 Ed. Law Rep. 18 (2001). As the court there explained, the activity of a
private party may be state action when:
1) it results from the states exercise of coercive power; or
2) the state provides significant encouragement, either overt or covert; or
3) a private actor operates as a willful participant in joint activity with the state or its agents; or
4) it is controlled by an agency of the state; or
5) it has been delegated a public function by the state; or
2012 Thomson Reuters. No claim to original U.S. Government Works.

CCPCIVILRGHTS, 7:8. State action test, Cal. Civ. Prac. Civil Rights Litigation 7:8

6) it is entwined with government policies or

7) when government is entwined in the management or control of the private actor.
While these factors are important, the court also cautioned that no one fact can function as a necessary condition across the
board for finding state action, or is any set of circumstances absolutely sufficient. Brentwood Academy v. Tennessee
Secondary School Athletic Assn, 531 U.S. 288, 29596, 121 S. Ct. 924, 148 L. Ed. 2d 807, 151 Ed. Law Rep. 18 (2001).
A relevant example of how a court analyzes a state action problem can be found in Florer v. Congregation Pidyon Shevuyim,
N.A., 639 F.3d 916 (9th Cir. 2011). In the Florer case, the plaintiff was a prisoner who complained that a private organization
had violated his rights by not providing appropriate religious services. The court refused to find state action, noting that the
inquiry begins with the presumption that conduct by private actors is not state action. [Florer v. Congregation Pidyon
Shevuyim, N.A., 639 F.3d 916, 922 (9th Cir. 2011)] The court did not find a close nexus between the private
congregations actions and any particular state policy; moreover, the court also found that the plaintiff could not show that
the defendant had exclusive dominion over the religious services that the state was bound to provide at the prison. The
plaintiff failed to show that any law or policy restricted him from receiving a Torah, calendar, or rabbi visit from persons or
organizations other than Defendants. [Florer v. Congregation Pidyon Shevuyim, N.A., 639 F.3d 916, 925 (9th Cir. 2011)]
While the defendants were under contract to provide certain services, they were not the exclusive avenue for the plaintiff to
exercise his religious beliefs and because there was no joint activity and the action in question was not the public
function of the state (nor could it be, given the strictures of the First Amendments Establishment Clause); hence, there was
no state action. The case is a good discussion of the major factors to analyze in these cases.
Westlaw. 2012 Thomson Reuters. No Claim to Orig. U.S. Govt. Works.
End of Document

2012 Thomson Reuters. No claim to original U.S. Government Works.

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The kickbacks usually consist of "rubberstamped" court orders which are contrary to
established law, and cannot be attributed to the
exercise of judicial discretion.For a detailed
overview of the alleged collusion between judge
pro tem attorneys and family court employees
and judges, we recommend our specialColor of
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The Color of Law series reports catalog some of

the preferential treatment provided by family
court employees and judges to SCBA Family
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Sacramento Family Court reform advocates assert that collusion

between judges and local attorneysdeprives financially disadvantaged,
unrepresented pro per court users of their parental rights, community
assets, and due process and access to the court constitutional rights.

The current day Sacramento County Family Court system andattorney operated settlement conference program
was set up in 1991 by and for the lawyers of theSacramento County Bar Association Family Law Section,

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according to the sworn testimony of controversial family court Judge Peter J. McBrien at his
2009Commission on Judicial Performance disciplinary proceedings. Click here to read Judge McBrien's
testimony.

In his own testimony during the same proceedings, local veteran family law attorney and judge pro tem Robert J.
O'Hair corroborated McBrien's testimony and attested to McBrien's character and value to Sacramento County
Bar Association Family Law Section members. Click here to view this excerpt of O'Hair's testimony. To view
O'Hair's complete testimony, click here.

Court watchdogs assert that the settlement conference kickback arrangement between the public court and private
sector attorneys constitutes a racketeering enterprise which deprives the public of the federally protected right
to honest government services.

Court reform and accountability advocates assert that the local family law bar- through the Family Law
ExecutiveCommitteeor FLEC - continues to control for the financial gain of members virtually all aspects of court
operations, and have catalogued documented examples of judge pro tem attorney preferential treatment and
bias against unrepresented litigants and"outsider" attorneys,including:
Divorce Corp, a documentary film that "exposes the corrupt and collusive industry of family law in
the United States" was released in major U.S. cities on January 10, 2014. After a nationwide search for
the most egregious examples of family court corruption, the movie's production team ultimately included
fourcases from Sacramento County in the film, more than any other jurisdiction.Judge pro tem
attorneys Charlotte Keeley, Richard Sokol, Elaine Van Beveren and Dianne Fetzer are each
accused of unethical conduct in the problem cases included in the movie. The infamous Carlsson case,
featuring judge pro tem attorney Charlotte Keeley and Judge Peter McBrien is the central case
profiled in the documentary, with Sacramento County portrayed as theGround Zeroof family court
corruption and collusion in the U.S. Click here for our complete coverage of Divorce Corp.
Judge Thadd Blizzard issued a rubber-stamped, kickback order in November, 2013 for judge pro tem
attorney Richard Sokol authorizing an illegal out-of-state move away and child abduction by Sokol's
client, April Berger. The opposing counsel is an "outsider" attorney from San Francisco who was
dumbfounded by the order. Click here for our exclusive report, which includes the complete court
reporter transcript from the hearing. Click here for our earlier report on the unethical practice of
"hometowning" and the prejudicial treatment of outsider attorneys.
Whistleblower leaked court records indicate that Sacramento Bar Association Family Law
Executive Committee officer and judge pro tem attorney Paula Salinger engaged in obstruction of
justice crimes against an indigent, unrepresented domestic violence victim. The victim was a witness in
a criminal contempt case against a Salinger client. The circumstances surrounding the obstruction of
justice incident also infer collusion between Salinger and controversial Judge Matthew J. Gary. For
our complete investigative report,click here.

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WE SUPPORT

Two "standing orders" still in effect after being issued by Judge Roland Candee in 2006 override a
California Rule of Court prohibiting temporary judges from serving in family law cases where one party
is self-represented and the other party is represented by an attorney or is an attorney. The orders were
renewed by Presiding Judge Laurie M. Earl in February, 2013.Click here for details.

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Sacramento Family Court judges ignore state conflict of interest laws requiring them to disclose to
opposing parties when a judge pro tem working as a private attorney represents a client in family
court. Click here for our exclusive investigative report. Click here for a list of other conflict of interest
posts.

Californians Aware

Family court policies and procedures, including local court rules, are dictated by the SCBA Family Law
Executive Committeefor the financial benefit of private sector attorneys, and often disadvantage the
70 percent of court users without lawyers, according to family court watchdogs and whistleblowers.
For example, in sworn testimony by Judge Peter McBrien before the Commission on Judicial
Performance,McBrien described seeking and obtaining permission from FLEC to change a local rule.
Click here and here.
In November, 2012 Sacramento Family Court Judge Jaime R. Romanissued a rubber-stamped,
kickback orderdeclaring a family court party a vexatious litigant and ordering him to pay $2,500 to
the opposing attorney, both without holding the court hearing required by law. The opposing attorney
who requested the orders is Judge Pro Tem Charlotte Keeley. The blatantly illegal orders resulted in
both an unnecessary state court appeal and federal litigation, wasting scarce judicial resources and
costing taxpayers significant sums.Click here for our exclusive coverage of the case.
Judge Matthew Gary used an unlawful fee waiver hearing to both obstruct an appeal of his own orders
and help a client of judgepro tem attorney Paula Salinger avoid paying spousal support. Click here for
our investigative report.
An unrepresented, disabled 52-year-old single mother was made homeless by an illegal child support
order issued by Judge Matthew Gary for SCBA Family Law Section attorney Tim Zeff, the partner of

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temporary judge Scott Buchanan. The rubber-stamped, kickback child supportorder, and other
proceedings in the case were so outrageous that the pro per is now represented on appeal by a team
of attorneys led by legendary trial attorney James Brosnahan of global law firm Morrison & Foerster.
For our exclusive, ongoing reports on the case, click here.
Judge pro tem attorneys Richard Sokol and Elaine Van Beverenhelped conceal judge misconduct
and failed to comply with Canon 3D(1) of the Code of Judicial Ethics when they were eyewitnesses to
an unlawful contempt of court and resisting arrest incident in Department 121. Both Sokol and Van
Beveren failed to report the misconduct of Judge Matthew Gary as required by state law.Van
Beveren isan officer of the SCBA Family Law Executive Committee.Click here for our exclusive
report...
...Four years later, Sokol and Van Beveren in open court disseminated demonstrably false and
misleading information about the unlawful contempt of court and resisting arrest incident. The
apparent objective of the judge pro tem attorneys was to discredit the victim of Gary's misconduct,
trivialize the incident, and cover up their own misconduct in failing to report the judge. For our follow-up
reports, click here. In 2014, a video of the illegal arrest and assault was leaked by a government
whistleblower. Click here for details.

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In 2008controversial family courtJudge Peter J. McBriendeprived a family court litigant of a fair trial
in a case where the winning party was represented by judge protemattorney Charlotte Keeley. In a
scathing, published opinion, the 3rd District Court of Appealreversed in full and ordered a new
trial. 6th District Court of Appeal Presiding Justice Conrad Rushing characterized McBrien's
conduct in thecase as a "judicial reign of terror."McBrien subsequently was disciplined by the
Commission on Judicial Performance for multiple acts of misconduct in 2009.Click here to read the
court of appeal decision. Click here to read the disciplinary decision issued by the CJP.
Judge pro tem attorneysCamille Hemmer,Robert O'Hair,Jerry GuthrieandRussell Carlsoneach
testified in support ofJudge Peter J. McBrienwhen thecontroversialjudge was facing removal from
the bench by theCommission on Judicial Performancein 2009.As a sworn temporary judges aware
of McBrien's misconduct, each wasrequired byCanon 3D(1)of theCode of Judicial Ethicsto take or
initiate appropriate corrective action to address McBrien's misconduct. Instead, each testified as a
character witnessin supportof the judge. In theCJP'sfinal disciplinary decision allowing McBrien to
remain on the bench, theCJPreferred specifically to the testimony as a mitigating factor that reduced
McBrien's punishment.Click here. Court records indicate thatJudge McBrienhas not disclosed the
potentialconflict of interestto opposing attorneys and litigants in subsequent appearances by the
attorneys in cases before the judge.Click hereforSFCNcoverage of conflict issues.
Judge pro temattorneysTerri Newman,CamilleHemmer,Diane WasznickyandDonna

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Reedwereinvolved in a proposedscheme to rig a recall electionofcontroversialJudgePeter J.

McBrienin 2008. The plan involved helping McBrien defeat the recall by electing him "Judge of the
Year" before the November election.Click herefor theSacramento News and Reviewreport.
Judge pro tem attorney Robert J. O'Hair testified as a character witness for controversial Judge Peter
J. McBrien at the judge's second CJP disciplinary proceeding in 2009.Paula Salinger, an attorney
at O'Hair's firm,Woodruff, O'Hair Posner & Salingerwas later granted a waiver of the requirements to
become ajudge pro tem. A family court watchdog asserts the waiver was payback for O'Hair's
testimony for McBrien.Click hereto read our exclusive investigative report.

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In cases where one party is unrepresented, family court clerks and judges permit judge pro tem
attorneys to file declarations which violate mandatory state court rule formatting requirements. The
declarations- on blank paper and without line numbers - make it impossible for the pro per to make
lawful written evidentiary objections to false and inadmissible evidence. Click here for our report
documenting multiple state court rule violations in a motion filed bySCBA Family Law Section officer
and temporary judgePaula Salinger. To view the pro per responsive declaration objecting to the illegal
filing click here, and click here for the pro per points & authorities.
Family court clerks and judges allow judge pro tem attorneys to file a fabricated "Notice of Entry of
Findings and Order After Hearing" in place of a mandatory Judicial Council Notice of Entry of
Judgment FL-190 form. The fake form omits critical appeal rights notifications and other information
included in the mandatory form. Click here for our exclusive report.
Sacramento Family Court temporaryjudgeandfamily law lawyerGary Appelblatt was charged with
13-criminal counts including sexual battery and penetration with a foreign object. The victims were
clients and potential clients of the attorney.The judge pro tem ultimately pleaded no contest to fourof
the original 13-counts, including sexual battery, and was sentenced to 18-months in prison. Court
administrators concealed from the public that Appelblatt held the Office of Temporary Judge.Click
hereto read our report.

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Judge pro tem and SCBA Family Law Section attorneyScott Kendall was disbarred from the practice
of law on Nov. 24, 2011. Kendall was disbarred for acts of moral turpitude, advising a client to violate
the law, failing to perform legal services competently, and failing to keep clients informed, including not
telling a client about a wage garnishment order and then withdrawing from the same case without
notifying the client or obtaining court permission. Court administrators concealed from the public that
Kendall held the Office of Temporary Judge.Click here to view our report.

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Judge pro tem attorneys Nancy Perkovich and Jacqueline Estonin 2008 helped Donna Gary - the
wife of Judge Matthew J. Gary - promote and market ClientTickler, a client management software
program for attorneys. The judge reportedly has never disclosed the conflict of interest as required by
the Code of Judicial Ethics. Click here for our exclusive report on the controversy.
In February, 2013 the website of family law firm Bartholomew & Wasznicky cut off the public from the
only online access to The Family Law Counselor, a monthly newsletter published by the Sacramento
Bar Association Family Law Section. Lawyers at the firm include judge pro tem attorneys Hal
Bartholomew, Diane Wasznicky and Mary Molinaro. As SFCN has reported, articles in the
newsletter often reflect an unusual, collusive relationship between SCBA attorneys and court
administrators and judges.Click here for our report.
Family court reform advocates assert that judge pro tem attorneys obtain favorable court rulings on
disputed issues at a statistically improbable rate. The collusion between full-time judges and judge pro
tem attorneys constitutes unfair, fraudulent, and unlawful business practices, all of which are
prohibited under California unfair competition laws, including Business and Professions Code
17200, reform advocates claim.

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Unfair competition and the collusion between judges and judge pro tem attorneys ultimately results in
unnecessary appeals burdening the appellate court system, and other, related litigation that wastes
public funds, exposes taxpayers to civil liability, and squanders scarce court resources.
Watchdogs point out that the court operates what amounts to a two-track system of justice. One for
judge pro tem attorneys and another for unrepresented, financially disadvantaged litigants and
"outsider attorneys." Two-track systems are prohibited by the Code of Judicial Ethics, according to
the Commission on Judicial Performance and the California Judicial Conduct Handbook, the gold
standard reference on judge misconduct.Click here for articles about the preferential treatment given
judge pro tem attorneys. Click here for examples of how pro pers are treated.
After representing a client in Sacramento Family Court, San Francisco attorney Stephen R. Gianelli
wrote "this is a 'juice court' in which outside counsel have little chance of prevailing...[the] court has now
abandoned even a pretense of being fair to outside counsel." Click here to read Gianelli's complete,
scathing account.
The Sacramento County Bar Association Family Law Section is led by an "Executive Committee"
("FLEC") of judge pro tem attorneys composed ofChair Russell Carlson, Vice Chair Elaine Van
Beveren, Treasurer Fredrick Cohen and Secretary Paula Salinger. Three of the four have been
involved in legal malpractice litigation, violations of the Code of Judicial Ethics, or as a defendant in
federal civil rights litigation. Click here to read SFCN profiles of the Executive Committee members.
Click here for otherarticles about FLEC.
Judge pro tem attorneys are by law required to take or initiate corrective action if they learn that
another judge has violated any provision of the Code of Judicial Ethics, or if a lawyer has violated any
provision of the California Rules of Professional Conduct. Family court watchdogs assert that
temporary judges regularly observe unethical and unlawful conduct by family court judges and attorneys
but have never taken or initiated appropriate corrective action, a violation of the judge pro tem oath of

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office. To view the applicable Code of Judicial Ethics Canons,Click here. For a Judicial Council
directive about the obligation to address judicial misconduct, a critical self-policing component of the
Code of Judicial Ethics, click here.

For information about the role of temporary judges in

family court,click here.For officialSacramento County
Superior Courtinformation about theTemporary Judge
Program click here.

Using public records law, Sacramento Family Court

News obtained the list of private practice attorneys
who also act as judge pro tems in Sacramento Family
Law Court. Each lawyer on the list below is currently a
temporary judge, or was a temporary judge in 2009,
2010, 2011, 2012 or 2013.SFCN cross-checked each
name on the Sacramento Countyjudge pro tem list
withCalifornia State Bar Data. The first name in each
listing is the name that appears on the Sacramento
County judge pro tem list, the second name, the State
Bar Number (SBN), and business address are derived
from the officialState Bar data for each attorney. The
State Bar data was obtained using thesearch function
at the State Bar website.

MISCONDUCT
(35)

ATTORNEYS
(11)
BAR
ASSOCIATION
(11)
BARACK
OBAMA
(1)
BARTHOLOMEW
and WASZNICKY
(3)
BUNMI
AWONIYI

(1)

CALIFORNIA

JUDICIAL CONDUCT HANDBOOK

(1)
CALIFORNIA

LAWYER
(1)

CALIFORNIANS AWARE
(2)

CAMILLE HEMMER
(3)

CANTIL-SAKAUYE
(5)

CARLSSON CASE
(10)

CECIL and CIANCI

(2)
CEO

(4)

CHARLOTTE
KEELEY
(18)
CHILD
CUSTODY
(22)
CHILD

SUPPORT
(4)
CHRISTINA

ARCURI
(5)
CHRISTINA
VOLKERS
(8)
CIVICS
(1)

CIVIL LIABILITY
(1)
CIVIL
RIGHTS
(6)
CJA
(3)
CJP

(18)
ClientTickler
(2)
CNN
CODE OF JUDICIAL
ETHICS
(12)
CODE OF

(1)

SILENCE
(2)
COLLEEN
MCDONAGH
(3)
COLOR OF

A number of family court whistleblowers have leaked court

recordsindicating that judge pro tem attorneys receive from
judges kickbacks and otherpreferential treatment in exchange
for operating the familycourt settlement conference program.

For-profit, private sector

lawyers who also hold the
Office of Temporary Judge:

Sandy

LAW
SERIES

(11)

CONFLICT OF INTEREST

(11)
CONSTITUTIONAL
RIGHTS
(3)
CONTEMPT
(5)

COURT CONDITIONS
(2)

COURT EMPLOYEE
(1)
COURT
EMPLOYEE CODE OF ETHICS
(1)

COURT POLICIES
(1)
COURT
RULES
(4)
COURTS
(1)
CPG

FAMILY LAW
(1)
CRIMINAL
CONDUCT
(11)
CRIMINAL

Amara, Sandra Rose Amara, SBN 166933, Law Office of Sandra Amara,1 California

LAW
(3)
CRONYISM
(2)

Street,Auburn, CA95603.

DAVID KAZZIE
(4)
DEMOTION

Mark

Ambrose, Mark Anthony Ambrose, SBN 141222, Law Offices of Mark A. Ambrose, 8801

Folsom Blvd. Ste. 170, Sacramento, CA 95826. Ambrose unethically advertises himself as a temporary judge.

Kathleen Amos, Kathleen Swalla Amos, SBN 112395, Attorney at Law & Mediator,206 5th
Street, Ste. 2B Galt, CA 95632.

Gary Appelblatt, Gary Michael Appelblatt, SBN 144158, 3610 American River Drive #112,
Sacramento, CA 95864. Appelblatt was disbarred by the State Bar on Sept. 24, 2010 afterbeing convicted of
sexual battery against clients. Click here for our exclusive report. Appelblatt is a graduate of McGeorge School of
Law.

Beth

(1)
DENISE

GARY
(2)
DSM-301.7
(1)
EDITORIAL
(1)
EDWARD
FREIDBERG
(2)
EFF
(2)

EFFICIENCY

IN

GOVERNMENT

ELAINE VAN
BEVEREN
(13)
ELECTIONS
(1)
AWARD
(1)

Appelsmith, Beth Marie Appelsmith, SBN 124135,1430 Alhambra Blvd. Sacramento CA

95816.

RICHARDS
(1)

DIANE WASZNICKY
(2)

DISQUALIFICATION
(2)

DIVORCE
(7)
DIVORCE
ATTORNEY
(5)
DIVORCE
CORP
(15)
DIVORCE
LAWYER

(5)

DOCUMENTS
(16)

DONALD TENN
(3)
DONNA

EMILY

GALLUP

(3)

EMPLOYEE CODE OF ETHICS

Bunmi Awoniyi, Olubunmi Olaide Awoniyi, SBN 154183, Law Office of Bunmi Awoniyi a
PC,1610 Executive Ct. Sacramento, CA 95864. Awoniyi unethically advertises herself as a temporary judge.
Awoniyi was appointed a Superior Court Judge in December 2012 and holds court in Department 120 of
Sacramento Family Court.

Alexandre C. Barbera, C. Alexandre Barbera, SBN 70071,915 Highland Point Drive, Ste. 250

(4)

EMPLOYEE
MISCONDUCT
(19)

EQUAL PROTECTION
(2)

EUGENE L. BALONON
(1)

EVIDENTIARY OBJECTIONS

(2)
EX PARTE
(1)
F4J
(4)

FAMILY COURT
(9)
FAMILY
COURT

Roseville, CA 95678.

COURT

AUDITS
(1)
FAMILY

CONDITIONS
(2)

FAMILY COURT

MEDIA COVERAGE

(1)
FAMILY COURT PROCEDURE

(1)

FAMILY
COURT
SACRAMENTO
(2)
FAMILY