The California Court of Appeal has affirmed a ruling that maintains psychologist Morella Bombardini's probation following her conviction for insurance fraud. The court's decision, filed on October 6, 2026, comes after Bombardini challenged both her 2021 probation and a 2024 petition for early termination of that probation. This ruling holds significance for licensed professionals facing disciplinary actions, as it underscores the importance of compliance with ethical standards and the legal processes governing professional conduct.
Morella Bombardini, who has been a licensed psychologist since 2011, found herself in legal trouble after being convicted in 2018 for making a fraudulent workers' compensation claim. The California Board of Psychology placed her on probation for five years in 2021 due to this conviction. In 2024, Bombardini sought to terminate her probation early, but the Board denied her request, stating she had not demonstrated sufficient rehabilitation. Bombardini subsequently appealed the Board's decisions, leading to the recent court ruling.
The dispute began when the Board of Psychology accused Bombardini of unprofessional conduct based on two grounds: her 2018 conviction for violating the Insurance Code and her failure to disclose a previous conviction from 1984 for writing a check with insufficient funds when applying for her license. Although the Board dismissed the latter charge, it upheld the first, resulting in the probationary period. Bombardini's legal challenges to these decisions were ultimately unsuccessful, as the court found her appeal regarding the 2021 decision was untimely and the 2024 decision was supported by substantial evidence.
The court ruled that Bombardini's appeal was not filed within the required 30 days after the Board's 2021 decision, which placed her on probation. The court noted, "Bombardini did not timely challenge the Board’s 2021 disciplinary order, and she cannot do so now under the guise of challenging the 2024 decision." This ruling emphasizes the importance of adhering to procedural timelines in legal matters.
In its examination of the 2024 decision, the court found that Bombardini failed to provide clear and convincing evidence of her rehabilitation. The Board had defined rehabilitation as a state of mind that includes an appreciation of the gravity of the misconduct and an acceptance of responsibility for it. The Board concluded that Bombardini lacked this state of mind, as she continued to deny her criminal conduct and expressed feelings of being unfairly punished. The court upheld this determination, stating, "The Board found Bombardini was missing this state of mind. Instead of accepting responsibility for the misconduct, she testified she was not a criminal, she was being unfairly punished."
This ruling has significant implications for licensed professionals in California. It reinforces the Board of Psychology's authority to impose disciplinary measures on licensees who engage in unprofessional conduct, particularly in cases involving fraud or dishonesty. Furthermore, it highlights the necessity for individuals seeking to modify or terminate probation to demonstrate genuine rehabilitation and compliance with the Board's conditions.
Moving forward, Bombardini's case serves as a reminder for licensed professionals to maintain ethical standards and to be aware of the legal processes surrounding disciplinary actions. The court's decision may also influence future cases involving similar circumstances, as it sets a precedent for how the courts will handle appeals related to professional licensing and disciplinary actions.
As for Bombardini, she has the option to appeal the court's decision. However, the likelihood of success in such an appeal remains uncertain, given the court's firm stance on the procedural and substantive issues at hand. The Board of Psychology's disciplinary actions and the court's subsequent rulings will continue to shape the landscape for licensed professionals in California.