Fratangelo v. Olsen
Petitioners sought certiorari to quash a non-final order entered after a bench trial in which a successor judge revisited and reversed a predecessor judge's partial summary judgments and partial final judgment on a release, found an unpled partnership, and ordered a third trial for equitable accounting. The Third DCA dismissed the petition for lack of the threshold jurisdictional showing of irreparable harm, holding that claimed reputational injury and prospective lost business are too speculative, and added that a successor judge may vacate or modify a predecessor's interlocutory rulings before final judgment. Chief Judge Rothenberg dissented at length, arguing the mid-trial reversals without notice denied due process and that compelled disclosure of personal financial records was 'cat out of the bag' irreparable harm.
Key facts
- Petitioners sought certiorari to quash a non-final order entered after bench trial in which successor judge reversed predecessor judge's partial summary judgments and partial final judgment on a release and found an unpled partnership.
- After the mid-trial reversals, the successor judge ordered a third trial for equitable accounting, which would require disclosure of petitioners' personal financial records.
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Why it matters
Useful authority for defending against interlocutory certiorari attacks: it reaffirms that irreparable harm is a jurisdictional threshold and that reputational/prospective-business harm will not satisfy it. It also… — full analysis with a trial
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