Dombrower v. Jingco — Third District affirmed the non-final order based on inadvertent disclosure and resulting tactical advantage

Case
Victoria Dombrower, et al. v. Jennifer Jingco, et al.
Court
Florida Third District Court of Appeal
Judge
MILLER; GORDO; BOKOR
Date Decided
October 29, 2026
Docket No.
3D26-1572
Topics
Disqualification, Inadvertent Disclosure, Non-Final Orders
Source
Read the full opinion

Background

Victoria Dombrower and the other appellants sought review of a non-final order entered by Judge Migna Sanchez-Llorens in the Circuit Court for Miami-Dade County. The Third District’s brief opinion does not describe the underlying claims, the material disclosed, or the precise terms of the challenged order.

The appellate court cited Abamar Housing & Development, Inc. v. Lisa Daly Lady Decor, Inc., a decision addressing disqualification after an inadvertent disclosure, a party’s failure to rectify the disclosure, and the resulting unfair tactical advantage. That authority states that a separate showing of prejudice is unnecessary under those circumstances.

The Court’s Holding

The Third District affirmed the non-final order without further analysis. Its citation to Abamar indicates that the court found that decision controlling or sufficiently analogous to support affirmance.

Under the cited rule, a disqualification motion may be adequate when it identifies the effects of an inadvertent disclosure, the opposing party’s recalcitrance in correcting the disclosure, and an unfair tactical advantage gained from it. The movant need not additionally demonstrate prejudice.

Key Takeaways

  • The Third District affirmed the circuit court’s non-final order.
  • The court relied on precedent concerning disqualification following inadvertent disclosure and an unfair tactical advantage.
  • Under the cited precedent, no separate showing of prejudice is required when the relevant grounds for disqualification are adequately established.

Why It Matters

The decision reinforces that Florida litigants who receive inadvertently disclosed material must address the disclosure appropriately rather than exploit it for tactical benefit. A failure to rectify the situation can support disqualification even without proof of additional prejudice.

Because the opinion is a citation affirmance and provides few case-specific facts, its principal significance lies in its application of Abamar rather than in any newly announced legal rule.

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