The California Court of Appeal recently upheld the Board of Psychology's decision to deny early termination of probation for psychologist Morella Bombardini. The court's ruling, issued on October 6, 2026, affects Bombardini's ability to practice psychology and underscores the Board's authority in licensing and disciplinary matters.
Morella Bombardini, a licensed psychologist, faced disciplinary action from the Board of Psychology after being convicted of insurance fraud in 2018. The Board placed her on probation for five years in 2021 and later denied her petition for early termination of that probation in 2024. The court's decision affirms the Board's actions and highlights the importance of public safety in the licensing of healthcare professionals.
Background
The dispute centers around Bombardini's professional conduct and her interactions with the Board of Psychology. In December 2019, the Board filed an accusation against her, citing two grounds for discipline: a 2018 conviction for violating Insurance Code section 1871.4 related to fraudulent workers' compensation claims, and her failure to disclose a 1984 conviction for writing a check with insufficient funds when applying for her license in 2007.
During a hearing in 2020, the Board dismissed the second charge regarding the 1984 conviction but found sufficient grounds to discipline Bombardini based on her insurance fraud conviction. The Board revoked her license but stayed the revocation, placing her on probation with specific terms. Bombardini did not challenge the 2021 decision in a timely manner.
The Ruling
The court affirmed the trial court's decision to deny Bombardini's petition for writ of mandate, which sought to challenge both the 2021 and 2024 decisions of the Board. The court found that Bombardini's challenge to the 2021 decision was untimely, as she failed to file a petition within the required 30 days after the decision was mailed to her.
Regarding the 2024 decision, the court ruled that the Board's denial of Bombardini's petition for early termination of probation was supported by substantial evidence. The Board found that Bombardini did not demonstrate clear and convincing evidence of rehabilitation, which is necessary for early termination of probation. The opinion stated, "It is too soon to allow [her] to practice psychology without Board oversight," reflecting the Board's commitment to public safety.
Impact
This ruling has significant implications for Bombardini and other licensed professionals facing disciplinary actions. It reinforces the authority of the Board of Psychology to enforce disciplinary measures and highlights the importance of rehabilitation in the process of regaining professional privileges. The court's decision also underscores the necessity for licensed professionals to adhere to the terms of their probation and to timely challenge disciplinary actions.
The ruling serves as a reminder that the Board prioritizes public safety above all else when making decisions regarding the licensing and discipline of psychologists. It may also set a precedent for future cases involving similar challenges to Board decisions, emphasizing the importance of timely appeals and the burden of proof on the licensee.
What's Next
Bombardini has the option to appeal the court's decision to the California Supreme Court, although it is unclear if she will pursue this route. There are no related cases pending at this time.