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4th DCAAugust 26, 2026Affirmed in part, reversed in part, and remanded with instructions⭐ Notable

Unger v. Unger

Case No. 4D2025-2209

A disqualified trial judge entered a written contempt order that contained factual findings (concerning a prior 2021 contempt proceeding) never orally announced at the hearing held before disqualification. The Fourth DCA agreed the unannounced findings exceeded the 'ministerial act' exception, but rejected the appellant's request to void the entire order; instead it remanded for the initial judge to vacate and re-enter an amended order deleting only the unannounced findings.

Key facts

  • Appellant Unger challenged a contempt order entered by a trial judge after the judge had been disqualified, arguing the written order contained factual findings about a prior 2021 contempt proceeding that were never orally announced at the hearing.
  • The trial judge reduced the oral ruling to a written contempt order post-disqualification, but included additional factual findings and details that had not been articulated during the hearing held before disqualification occurred.
  • +2 more key facts with a free trial

Why it matters

This opinion narrows the practical consequence of the rule that a disqualified judge's post-disqualification substantive additions are void: rather than wholesale vacatur and a new hearing, the fix is a corrected order… — full analysis with a trial

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