-
1:4. DefendantsPrivate individuals and state action..., 1 State
and Local...
2012 Thomson Reuters. No claim to original U.S. Government
Works. 1
1 State and Local Government Civil Rights Liability 1:4 (2d
ed.)
State and Local Government Civil Rights Liability Database
updated December 2011
Ivan E. Bodensteiner; Rosalie Berger Levinson
Chapter 1. Protecting Federal Rights under Section 1983 II.
Coverage
Summary
1:4. DefendantsPrivate individuals and state action
requirement
In addition to creating a cause of action against government
officials, it is possible to bring suit against private individuals
under 1983 either because their conduct is deemed to be state
action or because they have conspired with government officials. As
to the first theory, because most 1983 claims assert constitutional
rights that entail a state action requirement, the under the color
of law issue and the state action issue often merge.1 The Supreme
Court has stated that where private individuals meet the state
action requirement of the Fourteenth Amendment they will be deemed
to be acting under the color of state law for purposes of 1983.2 In
Flagg Bros., Inc. v. Brooks,3 a creditor acting pursuant to the
U.C.C. self-help provision seized the plaintiffs property allegedly
in violation of the Fourteenth Amendment Due Process Clause.
Although an individual exercising his rights under state law is
acting under the color of state law, the Court held that there was
no Fourteenth Amendment state action. Several subsequent Supreme
Court decisions have further limited the concept of state action by
refusing to attribute private conduct to the state despite
significant government involvement with the private entity.4 This
trend is reflected in several lower court opinions holding that
neither state regulation nor funding of a private entity will
convert its conduct into state action.5 Further, neither government
approval or acquiescence in the private conduct will suffice.6
Although the Supreme Court has been generally reluctant to treat
the action of private parties as that of the state for purposes of
the Fourteenth Amendment, and it has been less than clear in
articulating a coherent doctrine, a review of Supreme Court
precedent indicates that private parties may be sued under 1983
under the following theories: (1) Joint Participation: In Lugar v.
Edmondson Oil Co.,7 the Supreme Court set forth a two-part test
whereby private individuals who act in joint participation with
government officials will be considered state actors.
First, the Court explained that the deprivation must be caused
by the exercise of some right or privilege
created by the State or by a rule of conduct imposed by the
State or by a person for whom the State is
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1:4. DefendantsPrivate individuals and state action..., 1 State
and Local...
2012 Thomson Reuters. No claim to original U.S. Government
Works. 2
responsible.8 Second, the defendant must fairly be said to be a
state actor.9 As to the latter, the Court inquires into
whether the defendant has acted together with or has obtained
significant aid from state officials.10 The Lugar analysis was
applied in Edmonson v. Leesville Concrete Co.11 to hold that a
private litigants
race-based exercise of peremptory jury challenges in a civil
action constitutes governmental action. Applying the Lugar standard
several lower courts have found that private individuals or
entities may be
viewed as state actors because of their involvement with
government officials.12 On the other hand, many federal courts
applying the Lugar analysis have concluded that a defendants
action
was not attributable to the state.13 In several of these cases,
it was held that the private individual did not truly act in
concert with government officials.
For example, the mere fact that a private citizen files a
complaint with the police department or asks that an
individual be arrested does not, without more, constitute the
type of concerted activity required by Lugar.14 The Supreme Court
decision in NCAA v. Tarkanian lends support to this narrow
approach. The fact that the
NCAA promulgated regulations governing the state universitys
athletic program, investigated alleged violations on the part of
the university, and concluded that the university had to suspend
its basketball coach or face sanctions did not justify the state
Supreme Courts conclusion that the NCAA was acting under the color
of state law.15
Reasoning that the NCAA and the state university acted more like
adversaries than like partners, the Court
rejected the joint participation theory.16 (2) Conspiracy: The
Supreme Court has held that where private individuals enter into a
conspiracy with state
officials to deprive persons of their rights, they may be joined
as defendants. In fact the Court held in Dennis v. Sparks17 that a
private citizen who bribes a judge may be sued under
1983 even though in that situation the judge himself enjoyed
absolute immunity from suit.18 Further, in Tower v. Glover19 it was
held that although the actions of a public defender do not subject
him to
liability, a public defender who conspires with state officials
will be deemed to be acting under the color of law.20
Similarly, although federal officials may not be sued under
1983, federal officials acting in concert with
state authorities may be sued.21 Counsel should be cautioned
that although the requirements of a conspiracy are fairly
stringent, private
individuals who fit within the joint participation theory of
state action may also be sued under 1983.22 Because of the overlap
between the doctrines, some lower courts have narrowly construed
the joint
participation theory to require a conspiratorial type of
relationship between the state and the private parties.23
Others, however, have explicitly rejected the notion that
evidence of a conspiracy is needed in order to sue private
individuals whose conduct is deemed to be state action.24
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1:4. DefendantsPrivate individuals and state action..., 1 State
and Local...
2012 Thomson Reuters. No claim to original U.S. Government
Works. 3
(3) Compulsion or Significant Encouragement: Although, as noted,
government approval or acquiescence in private conduct will not
transform this conduct into state action, where the state actually
compels the private party to engage in the proscribed conduct, 1983
liability will be triggered.25
(4) Government Function: The Supreme Court has held that a
private party will be deemed a state actor
where it performs an exclusive, traditional public function.26
On the other hand, the Supreme Court has narrowly construed this
doctrine to exclude private entities that
provide utility service,27 medical assistance,28 or education.29
Relying on the public function doctrine, lower courts have ruled
that volunteer firefighters should be viewed
as state actors.30 Similarly, private parties who assist the
police in carrying out their investigative functions will be bound
by
constitutional norms.31 More difficult are the cases involving
private entities who contract with the government to carry out
official
functions. Because the government is increasingly privatizing
the operation of jails and prisons, these cases are proliferating.
In West v. Atkins32 the Supreme Court held that a private physician
under contract with the state to provide medical services at a
state hospital is acting as a state actor for purposes of 1983.
Generally, where the government contracts out official functions
that implicate statutory or constitutional
duties, state action will be found.33 On the other hand, several
cases have held that those who contract with the state to carry out
state-sponsored
programs or to perform public functions do not necessarily
become state actors for all of their conduct.34 Further, note that
even where private parties are acting under the color of state law,
difficult questions
remain as to whether private individuals or entities will be
shielded by the defenses that protect government officials and
entities.35
(5) Symbiotic Relation/Entwinement: The Supreme Court has ruled
that where a private party enters into a
symbiotic relationship with the government, state action will be
found. In Burton v. Wilmington Parking Authority,36 a private owner
of a restaurant who leased space from a
governmental agency and who refused to serve African-Americans
was held subject to suit under 1983 where both the government and
the restaurant benefited from the lease arrangement.
The Court focused on the states overall relationship with the
private actor and determined that the state had
insinuated itself into a position of interdependence with the
private party.37 Since this 1961 case, the Supreme Court has never
again relied on the symbiotic relationship doctrine to
support a finding of state action. Similarly, lower courts have
consistently distinguished and narrowed Burton as a case where the
government
was actually profiting from the racially discriminatory
practices of the restaurant.38 Although the symbiotic relationship
theory appears dead, the Supreme Court in Brentwood Academy v.
Tennessee Secondary School Athletic Association39 held that a
nominally private statewide voluntary
-
1:4. DefendantsPrivate individuals and state action..., 1 State
and Local...
2012 Thomson Reuters. No claim to original U.S. Government
Works. 4
association that governs sports among public and private
secondary schools was a state actor because of the pervasive
entwinement of public institutions and public officials.
The Court relied on several factorspublic schools predominated
in the membership of the organization at
the time of the incident in question, public school officials
held all slots on the governing bodies, members of the State Board
of Education were assigned ex officio to serve as members of the
governing bodies, and the organizations employees were eligible for
membership in the state retirement system.
Further, the Court noted that there were no substantial
countervailing reasons not to apply constitutional
standards to the Associations actions.40 Some lower courts have
relied on Brentwoods entwinement theory to find state action.41
However, in many
cases the fact-intensive inquiry demanded by Brentwood has
resulted in findings of insufficient evidence to support
entwinement,42 or
(6) Judicial Intervention: In Shelley v. Kraemer43 the Supreme
Court found state action where white
property owners sued in a state court to enforce a racially
restrictive covenant and thus stop a sale between a willing buyer
and seller.
The Court reasoned that the state court had interjected itself
into the private dispute such that the judiciary
became the efficient, effective cause of the adverse treatment,
thus subject to Fourteenth Amendment restrictions.44
Subsequent rulings have limited Shelley to its unique facts,
namely judicial enforcement of racially restrictive
covenants.45
Practice Tip:
Although, as discussed earlier in this section, private
individuals or entities may sometimes be sued as defendants under
1983, the rules governing liability of private entities is less
certain. As discussed in 2:1 to 2:5, government officials may enjoy
absolute or qualified immunity from damages. Further, as discussed
in 1:6, 1:7, government entities cannot be held liable unless the
injury was inflicted pursuant to a policy or custom and they are
shielded from punitive damages. See 2:8. On the other hand, they do
not enjoy qualified immunity. See 2:7. The Supreme Court in two
cases, Wyatt v. Cole46 and Richardson v. McKnight,47 has ruled that
private individuals do not enjoy the qualified immunity available
to government defendants. It has not, however, provided guidance
regarding private entities. Generally the lower courts have ruled
that private entities are liable only if a policy or custom can be
established.48 There is disagreement, however, on the immunity
issue. While some courts have extended the Supreme Court rule
denying municipal immunity to private entities,49 others have
decided to award private defendants a good faith defense.50 There
has been little discussion as to whether punitive damages should be
available to private entities.51
Westlaw. 2011 Thomson Reuters. No Claim to Orig. U.S. Govt.
Works.
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Investigative Reporting, News, Analysis, Opinion &
Satire
Sacramento Family Court NewsHOME JUDGE PRO TEM RACKETEERING 3rd
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Sacramento Family Court News Exclusive Investigative ReportThis
investigative report is ongoing and was last updated in April,
2015.
As many of the articles on our main page reflect, Sacramento
Family Law Court whistleblowers and watchdogs contend that a
"cartel" of local family law attorneys receive kickbacks and other
forms of preferential treatment from family court judges,
administrators and employees because the lawyers are members of the
Sacramento County Bar Association Family Law Section, hold the
Office of Temporary Judge, and run the family court settlement
conference program on behalf of the court.
The kickbacks usually consist of "rubber-stamped" 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 special Color of Law series
of investigative reports.
The Color of Law series reports catalog some of the preferential
treatment provided by family court employees and judges to SCBA
Family Law Section judge pro tem lawyers. Click here to view the
Color of Law series. For a list of our reports about family court
temporary judges and controversies, click here.
The current day Sacramento County Family Court system and
attorney operated settlement conference program was set up in 1991
by and for the lawyers of the Sacramento County Bar Association
Family Law Section,
Sacramento Superior Court Temporary Judge Program
Controversy
Judge Pro Tem Attorney "Cartel" Controls Court Operations,
Charge Whistleblowers
Sacramento Family Court reform advocates assert that collusion
between judges and local attorneys deprives financially
disadvantaged, unrepresented pro per court users of their parental
rights, community assets, and due process and access to the court
constitutional rights.
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according to the sworn testimony of controversial family court
Judge Peter J. McBrien at his 2009 Commission 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 Executive Committee or 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 four cases 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 the Ground Zero of 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.
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.
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.
Family court policies and procedures, including local court
rules, are dictated by the SCBA Family Law Executive Committee for
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. Roman
issued a rubber-stamped, kickback order declaring 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 judge pro
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 support order, 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 Beveren
helped 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 is an 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.
In 2008 controversial family court Judge Peter J. McBrien
deprived a family court litigant of a fair trial in a case where
the winning party was represented by judge pro tem attorney
Charlotte Keeley. In a scathing, published opinion, the 3rd
District Court of Appeal reversed in full and ordered a new trial.
6th District Court of Appeal Presiding Justice Conrad Rushing
characterized McBrien's conduct in the case 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 attorneys Camille Hemmer, Robert O'Hair, Jerry
Guthrie and Russell Carlson each testified in support of Judge
Peter J. McBrien when the controversial judge was facing removal
from the bench by the Commission on Judicial Performance in 2009.
As a sworn temporary judges aware of McBrien's misconduct, each was
required by Canon 3D(1) of the Code of Judicial Ethics to take or
initiate appropriate corrective action to address McBrien's
misconduct. Instead, each testified as a character witness in
support of the judge. In the CJP's final disciplinary decision
allowing McBrien to remain on the bench, the CJP referred
specifically to the testimony as a mitigating factor that reduced
McBrien's punishment. Click here. Court records indicate that Judge
McBrien has not disclosed the potential conflict of interest to
opposing attorneys and litigants in subsequent appearances by the
attorneys in cases before the judge. Click here for SFCN coverage
of conflict issues.
Judge pro tem attorneys Terri Newman, Camille Hemmer, Diane
Wasznicky and Donna
Reed were involved in a proposed scheme to rig a recall election
of controversial Judge Peter J. McBrien in 2008. The plan involved
helping McBrien defeat the recall by electing him "Judge of the
Year" before the November election. Click here for the Sacramento
News and Review report.
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 & Salinger
was later granted a waiver of the requirements to become a judge
pro tem. A family court watchdog asserts the waiver was payback for
O'Hair's testimony for McBrien. Click here to 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 by SCBA Family Law Section officer and temporary judge Paula
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 temporary judge and family law lawyer
Gary 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 four of 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 here to read
our report.
Judge pro tem and SCBA Family Law Section attorney Scott 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.
Judge pro tem attorneys Nancy Perkovich and Jacqueline Eston in
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.
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 of Chair 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 other articles 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 official Sacramento County Superior Court
information about the Temporary 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 County judge pro tem list with California 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
official State Bar data for each attorney. The State Bar data was
obtained using the search function at the State Bar website.
For-profit, private sector lawyers who also hold the Office of
Temporary Judge:
Sandy Amara, Sandra Rose Amara, SBN 166933, Law Office of Sandra
Amara,1 California Street, Auburn, CA 95603.
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 after being convicted
of sexual battery against clients. Click here for our exclusive
report. Appelblatt is a graduate of McGeorge School of Law.
Beth Appelsmith, Beth Marie Appelsmith, SBN 124135, 1430
Alhambra Blvd. Sacramento CA 95816.
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 Roseville, CA 95678.
A number of family court whistleblowers have leaked court
records indicating that judge pro tem attorneys receive from
judges kickbacks and other preferential treatment in exchange
for operating the family court settlement conference program.
MISCONDUCT (35) ATTORNEYS (11) BAR ASSOCIATION (11)
CANTIL-SAKAUYE (5) CARLSSON CASE (10)
CHARLOTTE KEELEY (18) CHILD CUSTODY (22)
CHRISTINA ARCURI (5) CHRISTINA VOLKERS (8) CIVIL RIGHTS (6) CJP
(18)
CODE OF JUDICIAL ETHICS (12)
COLOR OF LAW SERIES (11) CONFLICT OF INTEREST (11)
CONTEMPT (5)
CRIMINAL CONDUCT (11)
DIVORCE (7) DIVORCE ATTORNEY (5) DIVORCE CORP (15) DIVORCE
LAWYER (5) DOCUMENTS (16)
ELAINE VAN
BEVEREN (13)
EMPLOYEE
MISCONDUCT (19)
FAMILY COURT (9)
BARACK OBAMA (1) BARTHOLOMEW and WASZNICKY (3) BUNMI AWONIYI (1)
CALIFORNIA JUDICIAL CONDUCT HANDBOOK (1) CALIFORNIA LAWYER
(1)CALIFORNIANS AWARE (2)
CAMILLE HEMMER (3)
CECIL and CIANCI (2) CEO (4)
CHILD SUPPORT (4)
CIVICS (1)CIVIL LIABILITY (1)
CJA (3) ClientTickler (2) CNN
(1) CODE OF
SILENCE (2) COLLEEN MCDONAGH (3)
CONSTITUTIONAL RIGHTS (3)
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 LAW (3) CRONYISM (2)DAVID KAZZIE (4) DEMOTION
(1) DENISE RICHARDS (1)DIANE WASZNICKY (2)DISQUALIFICATION
(2)
DONALD TENN (3) DONNA GARY (2) DSM-301.7 (1)
EDITORIAL (1) EDWARD FREIDBERG (2) EFF (2)
EFFICIENCY IN GOVERNMENT AWARD (1)
ELECTIONS (1) EMILY GALLUP (3)EMPLOYEE CODE OF ETHICS
(4)
EQUAL PROTECTION (2)EUGENE L. BALONON (1)
EVIDENTIARY OBJECTIONS (2) EX PARTE (1) F4J (4)
FAMILY COURT AUDITS (1) FAMILY COURT CONDITIONS (2)FAMILY COURT
MEDIA COVERAGE
(1) FAMILY COURT PROCEDURE (1) FAMILY COURT SACRAMENTO (2)
FAMILY
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