Edward Joseph Unger v. Jennifer Rose Unger
The Fourth District held that a disqualified judge who enters a written order after disqualification may perform only the ministerial act of reducing an already-announced oral ruling to writing, and that findings added beyond the oral pronouncement are substantive and void. It rejected the argument that the whole written order is void, holding instead that the correct remedy — where a transcript exists to show what was orally determined — is to vacate and re-enter an amended order stripped of the unannounced findings, rather than to order a new hearing before a new judge.
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