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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.

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