What is the test for standing to challenge a disability accommodation order?

As an initial matter, appellant has no standing to challenge the court's order, which granted his request for a 90-day continuance. In order to have standing to appeal, a party must be aggrieved by the challenged order or judgment. (Sabi v. Sterling (2010) 183 Cal.App.4th 916, 947.) The standing rule is jurisdictional. (Ibid.) When a party such as appellant prevails on the only matters presented to the trial court, that party is obviously not aggrieved by the court's decision. Appellant objects to the denial of various requested accommodations, such as his request for a change of venue, but there is no indication in the record that appellant ever sought a ruling from the trial court on these requests. Instead, they were the subject of a determination by the court manager, a nonjudicial court employee. Rule 1.100(g)(1) requires a person aggrieved by a nonjudicial court employee's determination of an accommodation request to timely seek review by an appropriate judicial officer in the court where the accommodation is sought. Under rule 1.100, a determination by a judicial officer on a request for a disability accommodation is a predicate to seeking review in a higher court. (See rule 1.100(g)(2).) In this case, the only disability accommodation request presented to the judge for decision was appellant's request for a continuance, which was granted. Because the court granted appellant the relief he requested on the only accommodation request submitted to the judge for consideration, appellant is not legally aggrieved by the court's order.

The appeal suffers from an even more fundamental problem, however, because a ruling on a disability accommodation request is not an appealable order. (See Civ. Proc., 904.1 [listing appealable judgments and orders].) The right to appeal is statutory, and " 'a judgment or order is not appealable unless expressly made so by statute.' " (People v. Mazurette (2001) 24 Cal.4th 789, 792.) We have no choice but to dismiss an appeal taken from a nonappealable order. (See Garau v. Torrance Unified School Dist. (2006) 137 Cal.App.4th 192, 202.)

Appellant seems to believe that his appeal is authorized as a petition for a writ of administrative mandate under Code of Civil Procedure section 1094.5. He is mistaken. Section 1094.5 of the Code of Civil Procedure governs judicial review of any final decision of an administrative agency. (Wences v. City of Los Angeles (2009) 177

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