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    When the Way Back to Practice Becomes Another Hearing: Lessons from Bombardini v. Board of Psychology

    The BoardWise TeamOctober 8, 2026

    A professional license can remain active on paper while the path back to work feels almost impossible.

    Probation may require a monitor, examinations, coursework, and reports. Employers may hesitate to hire someone carrying those restrictions. Time passes, bills accumulate, and the professional begins to wonder whether the discipline will ever end.

    For California psychologist Morella Bombardini, that tension eventually reached the California Court of Appeal, Third Appellate District. On October 6, 2026, the court affirmed the denial of her request to end probation early. The decision, *Bombardini v. Board of Psychology*, No. C104172, offers a consequential lesson about how the legal system sees a professional's attempt to return to unrestricted practice.

    It also reveals how easily a person can tell a deeply meaningful story about their experience while leaving the specific questions an agency needs answered unresolved.

    A disciplinary order with consequences that followed her

    According to the appellate opinion, Bombardini received her California psychologist license in 2011. In 2019, the Board brought an accusation containing two grounds for discipline: a 2018 workers' compensation insurance-fraud conviction and an allegation that she had failed to disclose a much older conviction when applying for licensure.

    The older-conviction allegation did not become a basis for discipline. The Board dismissed that charge because it had known about the conviction before issuing her license.

    The insurance-fraud conviction did become a basis for discipline. Although the conviction was dismissed under Penal Code section 1203.4 in 2019, the Board imposed discipline. The opinion explains that California's psychology licensing law permits reliance on a qualifying conviction notwithstanding that form of dismissal. A criminal-record dismissal and relief from professional discipline are separate legal questions.

    In 2021, the Board revoked her license, stayed the revocation, and placed her on five years of probation. Conditions included practice and billing monitoring, an examination, coursework, quarterly reports, and reimbursement of enforcement costs.

    The order also contained a provision with lasting consequences: periods outside California, or qualifying periods without practicing psychology in California, extended the probation term. Certain obligations continued while other provisions were held in abeyance.

    Bombardini moved to Maryland and later Oregon. The opinion reports that her applications for licensure in both states were denied. She returned to California in 2023 and petitioned to end probation early.

    The calendar had advanced. Her probation, however, had been tolled.

    That distinction matters for anyone reading an order that lasts a stated number of years. The date on the calendar does not necessarily establish the amount of probation credited under the order. The governing terms need to be read carefully.

    The hearing was about relief from an existing order

    At the early-termination hearing, Bombardini represented herself. The opinion describes testimony about her underlying medical condition, the advice she received during her criminal case, the financial consequences of discipline, and her desire to return to a profession she had long wanted to practice.

    Those consequences deserve to be taken seriously. Losing access to work can affect income, identity, stability, and a person's sense of belonging.

    The Board was nevertheless evaluating a particular request: whether she had demonstrated grounds to remove its oversight before the probationary term ended. It found that she had not demonstrated rehabilitation by clear and convincing evidence and noted that she had not completed practice-related conditions intended to establish safe practice.

    The difference between describing the harm caused by discipline and demonstrating entitlement to relief became central to the dispute.

    After the denial, Bombardini sought judicial review of both the original disciplinary order and the later early-termination decision. The trial court denied relief. The Court of Appeal affirmed.

    The published holding: an early-termination denial receives deferential factual review

    The opinion is only partially published. Its published discussion addresses the standard courts use to review the Board's denial of early termination. Parts II, III, and IV of the Discussion (covering the older conviction, the case-specific denial, and procedural-unfairness arguments) are unpublished.

    That boundary matters. Those sections explain what happened in this case, but should not be presented as independently citable California precedent, subject to the exceptions in California Rule of Court 8.1115.

    The published holding draws a distinction between imposing discipline on an existing license and refusing to remove conditions early.

    A timely challenge to discipline affecting an existing professional license may receive independent-judgment review of factual findings. Under that standard, the trial court weighs the evidence, subject to the applicable presumption favoring the agency's findings.

    But when Bombardini sought early termination, the right she already possessed was the right to practice subject to probation. She was asking for an unrestricted status she did not then hold. The court treated that request as more analogous to seeking reinstatement or an unrestricted license.

    It therefore held that substantial-evidence review applied to the denial. That standard gives the agency greater latitude on factual findings. A court does not simply replace the Board's assessment with the result it finds more persuasive. Questions of law remain subject to independent review.

    This ruling does not eliminate judicial review or give boards unlimited authority. It does make the administrative record especially important: the evidence presented to the Board, the findings it makes, and the relief actually requested will shape what a court can later examine.

    The request itself mattered

    One of the most revealing passages appears in the unpublished discussion.

    Bombardini argued that practice-based conditions were impossible to satisfy because employers would not hire her while she was on probation. Yet the court observed that she had asked the Board to terminate probation, without specifically asking it to modify or eliminate particular conditions.

    Even though the petition form referred to termination and modification, the relief described in her petition and requested at the hearing was termination. The court declined to decide the propriety of conditions she had not asked the Board to modify.

    For a professional preparing a petition, this illustrates a practical distinction. Ending all probation, changing one condition, and challenging the original order are different requests. A narrative explaining why a condition is difficult does not necessarily put a concrete request to change that condition before the agency.

    A useful preparation question is: What exactly am I asking the Board to order, and where have I clearly requested it?

    Modification is not necessarily available or appropriate in every situation, and this case does not promise that a different request would have succeeded. It shows why the requested relief deserves as much attention as the supporting story.

    Rehabilitation requires evidence that fits the question

    The Board's guidelines discussed in the opinion evaluate both attitude and conduct: an understanding of the misconduct and a demonstrated course of responsible behavior supporting safe practice. They describe a relief hearing as distinct from retrying the original disciplinary case.

    In its unpublished discussion, the court examined why it considered Bombardini's evidence insufficient. Some recommendation letters predated the relevant events and did not show that their authors knew about the misconduct. Her description of responsibility was also read alongside statements minimizing or disputing the conviction.

    The broader preparation lesson is about relevance and consistency. A supportive letter may need to explain what the writer knows, what they have personally observed since discipline, and how those observations relate to present fitness. A list of completed obligations may need supporting records and an explanation connecting those steps to the concerns identified in the order.

    This should never become an instruction to manufacture remorse, confess to conduct a person disputes, or abandon a legal defense. Where criminal proceedings, disputed facts, or possible admissions remain involved, an attorney can help assess the consequences of a proposed statement. Accuracy matters more than producing language that sounds agreeable.

    An earlier deadline cannot be assumed to reopen

    Bombardini had not timely sought judicial review of the 2021 disciplinary order. The later petition did not reopen that original challenge.

    That is a particularly difficult feature of administrative proceedings: a person may still be living with the consequences long after the window to challenge the original decision has closed.

    For a newly received order, identifying review deadlines should happen promptly. The calculation can depend on the applicable statute, delivery or mailing, effective date, reconsideration proceedings, record requests, and other circumstances. A general article cannot determine an individual's deadline.

    For an older order, it is equally important to identify the remedy still available. A request for modification or termination should be prepared around its own legal criteria rather than assuming it functions as a delayed appeal.

    What this case says about meaningful support

    The opinion does not tell us that every struggling licensee should remain on probation. It does not establish that financial hardship is unimportant. It shows how a person's lived experience and an agency's decision framework can diverge.

    A professional may arrive wanting the Board to understand what the process has cost them. The Board may be asking whether a particular condition can safely be removed, whether the relevant term has accrued, and whether the record establishes present fitness.

    Effective preparation helps connect those questions. It starts with the actual order, separates findings from dismissed allegations, identifies the relief sought, and organizes evidence around the criteria that govern that relief.

    BoardWise helps licensed professionals organize their matter, understand procedural questions, and prepare information for the next step. When a petition raises complex legal issues or a court challenge is contemplated, consultation with an attorney familiar with licensing matters can be especially valuable.

    The path back to practice deserves clarity. Professionals should be able to understand what they are being asked to demonstrate, what options remain available, and how to make a request the decision-maker can actually evaluate.

    Sources and editorial notes

    Editorial review: October 8, 2026. The official opinion listing identifies the decision as published; the opinion itself is certified for partial publication. No later modification was shown on that listing when reviewed. Check the official case record for later rehearing, review, or publication changes. The detailed analysis of hardship, letters, requested modification, and procedural unfairness is case reporting from unpublished sections, not a claim that those sections created new binding law. This article provides general education, not an assessment of an individual petition.