1:4. DefendantsPrivate individuals and state action..., 1 State and Local...

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

 1:4. DefendantsPrivate individuals and state action..., 1 State and Local...

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

 1:4. DefendantsPrivate individuals and state action..., 1 State and Local...

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

 1:4. DefendantsPrivate individuals and state action..., 1 State and Local...

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

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Judge Pro Tem Attorney "Cartel" Controls Court

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Sacramento Family Court News Exclusive Investigative Report

This investigative report is ongoing and was last updated in April, 2015.

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As many of the articles on our main page reflect,

Sacramento Family Law Court whistleblowers
and watchdogs contendthat a "cartel" of local
family lawattorneys receive kickbacks and other
forms ofpreferential treatment from family
courtjudges, administrators and
employeesbecause 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.

SCBA
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(19)
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CJP
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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
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.

DOCUMENTS
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COLOR OF LAW SERIES

(11)

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,

CONFLICT OF INTEREST

(11)
RAPTON-KARRES
(11)
SATIRE
(11)
WHISTLEBLOWERS
(11)
WOODRUFF O'HAIR
POSNER and SALINGER

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.

(11)
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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.

Electronic Frontier
Foundation

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

Local & National Family CourtFamily Law Sites & Blogs (may
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ABA Family Law Blawg
Directory
California Coalition for
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California Protective
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Center for Judicial
Excellence
Courageous Kids Network
Divorce & Family Law News
Divorce Corp

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
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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
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(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