On Wednesday, October 29, 2025, the California Commission on Judicial Performance publicly admonished Inyo County Superior Court Judge Susanne M. Rizo for multiple instances of misconduct.
The decision, reached after Judge Rizo contested a tentative admonishment issued in July, stems from incidents involving failure to cooperate with court staff, inappropriate comments about litigants, improper case dismissal, and a questionable probable cause determination.
The commission’s investigation revealed that Judge Rizo filed complaints with the State Bar of California against Court Executive Officer Pamela Foster and Court Operations Manager Lindsay Eropkin, alleging the unauthorized practice of law. These complaints also implicated Presiding Judge Stephen Place, the only other judge in Inyo County, for “aiding and abetting” the alleged misconduct.
Judge Rizo claimed that Foster and Eropkin challenged her directives regarding notice requirements in probate guardianship cases involving the Indian Child Welfare Act (ICWA). The State Bar dismissed the complaints, finding insufficient evidence of unauthorized practice of law. The commission concluded that Judge Rizo lacked a good faith basis for filing the complaints and that her actions gave the appearance of retaliation against the court staff.
Another instance of misconduct involved Judge Rizo’s handling of a request for leave. After informing court administration of a medical appointment, Judge Rizo reacted strongly to the suggestion that rescheduling her calendar would be “problematic,” even after a judge was found to cover. She accused the court of treating her medical concerns differently than those of the presiding judge and threatened legal action. The commission deemed her response volatile, disproportionate, and a failure to cooperate with court administration.
Judge Rizo was also found to have made inappropriate comments about litigants and their pending cases within earshot of court staff and the public. In one instance, after a hearing in Emisa Rinkevich v. Occean Hyles, Judge Rizo expressed distress and compassion for the petitioner’s situation in the clerks’ area, where the mother overheard the conversation and became visibly upset. This incident led to Judge Rizo’s recusal from the case. In another case, Ginger Haskin v. Cullen Daugherty, Judge Rizo spoke about the facts of the case before it was heard, in a manner that could be overheard by clerks.
Further, the commission cited an instance where Judge Rizo improperly dismissed a traffic infraction case, People v. William Calderon Jauregui, citing a lack of resources to verify the defendant’s arguments for dismissal and stating that she was sitting on an assignment she “normally [did]n’t sit on.” The commission found this to be a dereliction of her duty to perform judicial duties impartially and competently.
Finally, Judge Rizo was found to have made a probable cause determination in a case, People v. Angel Jacoba Schat, from which she was already recused due to a past campaign contribution from the litigant’s father. The commission emphasized that a judge with a disqualifying interest should not take any action in the matter, including making a probable cause determination.
The Commission on Judicial Performance determined that Judge Rizo’s actions constituted improper action, violating multiple canons of judicial ethics and undermining public confidence in the integrity and impartiality of the judiciary. The commission considered the numerous acts of misconduct and the contentious atmosphere created within the small Inyo County court in determining the appropriate discipline.
A copy of the original filing can be found here.
