Failure to State Remorse Caused Her Petition To Remove Probation to be Rejected
Probation for Workers’ Compensation Fraud Does Not Go Away Because Defendant claims the Admission was Made in Error
Post 4570
In Morella Bombardini v. Board Of Psychology, C104172, California Court of Appeals, Third District, Sacramento (October 6, 2026) Morella Bombardini, a licensed psychologist, pleaded no contest in 2018 to misdemeanor workers’ compensation insurance fraud involving fiscal dishonesty. In 2021, the Board of Psychology revoked her license, stayed the revocation, and imposed five years of probation with monitoring, examination, coursework, reporting, and cost-reimbursement conditions.
She did not timely seek judicial review of that order. After moving out of California, her probation was tolled. She later returned and petitioned for early termination. At the 2024 hearing, she emphasized an unrelated 1984 conviction, minimized the conduct underlying the 2018 conviction, attributed her plea to counsel, and maintained that she had not intended fraud.
The Board found that she had not shown rehabilitation by clear and convincing evidence and denied relief.
LAW
California’s Psychology Licensing Law makes public protection the Board’s highest priority and permits discipline for a substantially related conviction, including a crime involving fiscal dishonesty, and for conduct prohibited by Insurance Code section 1871.4.
Rehabilitation requires a mature appreciation of the gravity of the misconduct, acceptance of responsibility, remorse, and a reliable course of conduct demonstrating that unrestricted practice would be safe.
DISCUSSION
The Court of Appeal rejected four principal arguments.
First:
The trial court correctly used substantial-evidence review because the 2024 proceeding concerned early removal of existing probationary restrictions, not the original imposition of discipline.
Second:
The 1984 insufficient-funds conviction was irrelevant: the Board dismissed that charge in 2021 and relied only on the 2018 insurance-fraud conviction. Any direct challenge to the 2021 order was untimely.
Third:
The Board did not abuse its discretion. Bombardini had requested termination — not modification — of probation, so objections to particular conditions were not preserved. Her compliance, payment of costs, lack of new misconduct, character letters, financial hardship, and claimed inability to find work did not compel a finding of rehabilitation.
Fourth:
Alleged unfairness in the 2020 hearing could not revive an untimely challenge to the 2021 order and, in any event, was unsupported: self-representation was permitted after notice of the right to counsel, she had discovery and exhibit notice, and no hearing transcript substantiated prejudice from remote-connection problems.
ANALYSIS
The decision separates review of an original disciplinary order from review of a later request for relief. A licensee has a vested right in an existing license when discipline is first imposed, but after the discipline becomes final, the licensee has only the existing, restricted right and must justify an expansion to unrestricted practice.
Rehabilitation Is primarily a question of insight and accountability, not merely technical compliance or absence of later violations.
Because Bombardini continued to contest the moral and factual premise of the conviction, the Board could rationally conclude that she had not shown the state of mind required for safe, unsupervised practice.
CONCLUSION
The Court of Appeal affirmed the judgment because the 2021 disciplinary order could not be challenged after the statutory deadline, substantial evidence supported the Board’s 2024 finding that Bombardini had not proved rehabilitation by clear and convincing evidence, and the Board did not abuse its discretion in refusing to terminate probation early.
Bombardini testified, “I am not a criminal, but I really feel like I’m being treated as one.” , She also testified, “I didn’t think that this [i.e., the insurance fraud conviction] was going to come to this, to having my license on probation.” She then tried to justify her actions by claiming her lawyers were inadequate. The testimony suggested that Bombardini believed she did not actually commit insurance fraud. This testimony supports the Board’s finding that Bombardini “has yet to achieve th[e] necessary state of mind” to demonstrate rehabilitation because, “[s]he continues to deny her criminal conduct, claims she is being unfairly punished. She has yet to gain any insight into the misconduct that led to her license being placed on probation.”
ZALMA OPINION
A convicted felon who lost her license to practice because of the conviction for workers’ compensation fraud tried to have the probation removed by claiming she didn’t know that her admission of fraud was a crime and would keep her from working as a psychologist is just weak and not sufficient because she never accepted the fact that she committed fraud and that it was a crime. She lost because she failed to state remorse and for that reason her petition was rejected.
(c) 2026 Barry Zalma & ClaimSchool, Inc.
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