James Jarosz v. Stephen L. Palmer & another

Summary

The court reversed dismissal of Jarosz’s claims against his former attorney because the prior ruling denying disqualification did not have preclusive effect. Although the attorney-client-relationship issue was actually litigated, it was not essential to the merits of the underlying action, and the interlocutory disqualification ruling was not meaningfully subject to review. The later stipulation dismissing the underlying case with prejudice did not convert the interlocutory ruling into a preclusive final judgment.