Supreme Court of California · published May 28, 2026
J.O. v. Superior Court — a new framework for judicial disqualification
Justice Joshua Groban, writing for a unanimous court, concluded that Solberg v. Superior Court (1977) 19 Cal.3d 182 — which affirmed that blanket challenges do not substantially impair a court's duties — "is no longer tenable" given the realities of California's modern judiciary.
The opinion arose from a 2024 conservatorship in which San Joaquin County Counsel filed approximately 325 motions to disqualify Superior Court Judge Erin Guy Castillo after she admonished a deputy for misconduct. The subject, J.O., objected — and the high court now directs trial courts to employ a three-step procedure modeled on Batson v. Kentucky when evaluating whether repeated affidavit-based challenges are pretextual.