collateral order doctrine in California

2026If the trial court’s ruling on a collateral issue “‘is substantially the same as a final judgment in an independent proceeding’ [citation], in that it leaves the court no further action to take on ‘a matter which … is severable from the general subject of the litigation’ [citation], an appeal will lie from that collateral order even though other matters in the case remain to be determined.” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 561 .) An interlocutory order is appealable under the collateral order doctrine when it is “collateral to the main issue, dispositive of the rights of the parti

2026To be appealable under the collateral order doctrine, a court’s ruling on a collateral issue must “leave[] the court no further action to take .…” (Lester v. Lennane, supra, 84 Cal.App.4th at p. 561 ; accord, In re Marriage of Skelley, supra, 18 Cal.3d at p. 368 [collateral order doctrine requires a decision that finally determines the rights of the parties in relation to a collateral matter, leaving no further acts to be done by the court in regard to that matter].) As the court’s May 13, 2025, order, in conjunction with the tentative and final statements of decision regarding the accounts’ c

2025“Under California procedure there is ordinarily only one final judgment in an action.” (Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 118 .) But there are exceptions to this rule that include the collateral order doctrine that allows a party to appeal orders directing the payment of money.

2022(Marsh v. Mountain Zephyr (1996) 43 Cal.App.4th 289 , 297– 298, citing Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 ; accord, Reddish, at p. 278; (Koshak v. Malek (2011) 200 Cal.App.4th 1540, 1545 (Koshak).) In other words, under the collateral order rule, “ ‘an appeal will lie from [a] collateral order even though other matters in the case remain to be determined,’ but that exception applies only ‘[w]here the trial court’s ruling on a collateral issue “is substantially the same as a final judgment in an independent proceeding” [citation], in that it leaves the court no further action to take

2025(Madrigal, supra, 90 Cal.App.5th at p. 395; Apex LLC v. Korusfood.com (2013) 222 Cal.App.4th 1010, 1016 .) We conclude the trial court’s ruling on the division of the sale proceeds ordered in the statement of decision is not appealable under the collateral order doctrine.

2025Pritikin appealed the sanctions order under the collateral order doctrine because it is (1) “a final determination (2) of a collateral matter (3) and direct[s] the payment of money or performance of an act.” (Apex LLC v. Korusfood.com (2013) 222 Cal.App.4th 1010, 1016 (Apex).) 4 DISCUSSION I.

2026If the trial court’s ruling on a collateral issue “‘is substantially the same as a final judgment in an independent proceeding’ [citation], in that it leaves the court no further action to take on ‘a matter which … is severable from the general subject of the litigation’ [citation], an appeal will lie from that collateral order even though other matters in the case remain to be determined.” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 561 .) An interlocutory order is appealable under the collateral order doctrine when it is “collateral to the main issue, dispositive of the rights of the parti

2026To be appealable under the collateral order doctrine, a court’s ruling on a collateral issue must “leave[] the court no further action to take .…” (Lester v. Lennane, supra, 84 Cal.App.4th at p. 561 ; accord, In re Marriage of Skelley, supra, 18 Cal.3d at p. 368 [collateral order doctrine requires a decision that finally determines the rights of the parties in relation to a collateral matter, leaving no further acts to be done by the court in regard to that matter].) As the court’s May 13, 2025, order, in conjunction with the tentative and final statements of decision regarding the accounts’ c

2022The court further stated, “Separately and alternatively, however, even assuming an order taxing costs is no longer appealable as an order after judgment, we believe it is appealable under the collateral order doctrine.” (Krikorian, supra, 193 Cal.App.4th at p. 1083 .) “The effect of an order denying a motion to tax costs, in whole or in part, is that the moving party must pay the costs allowed.” (Id. at p. 1084.) The court declined to “decide whether an order taxing all costs, and thus awarding zero, would be immediately appealable.” (Id. at p. 1084, fn. 3.) Krikorian is consistent with Lachka

2021(Krikorian Premiere Theatres, LLC v. Westminster Central, LLC (2011) 193 Cal.App.4th 1075, 1083 [order taxing costs on appeal is independent of any determination of the merits, effectively final and immediately enforceable as to the 13 ancillary issue of costs on appeal, and could otherwise escape review entirely].) Although there is disagreement in the case law as to whether the collateral order doctrine requires an order directing the payment of money or performance of an act, assuming it is required, the Krikorian court found no meaningful difference between an order awarding costs and an o

2025The Trial Court’s Order Is Appealable as a Collateral Order Under the collateral order doctrine, an order on a collateral matter is appealable where it “ ‘leaves the court no further action to take on “a matter which . . . is severable from the general subject of the litigation.” ’ ” (Smith v. Smith (2012) 208 Cal.App.4th 1074, 1084 (Smith).) The trial court’s order is appealable on this basis. 1 As in Doe v. Massachusetts Institute of Technology (1st Cir. 2022) 46 F.4th 61, 72 (Massachusetts Institute of Technology), there is no indication in the record that any of the four parties have ever

2022(Smith, supra, 208 Cal.App.4th at p. 1083 .) However, the collateral order doctrine exists as a common law exception to the one final judgment rule pursuant to which “some interim orders are deemed appealable ‘judgments’ because they are essentially the same as a final judgment.” (Reddish v. Westamerica Bank (2021) 68 Cal.Ap.5th 275, 278; see Smith, supra, 208 Cal.App.4th at p. 1084 [the collateral order doctrine is a well-recognized “exception to the ‘one final judgment’ rule codified in . . . section 904.1”].) Pursuant to the doctrine, an interim order is appealable if: (1) it is collateral

2026If the trial court’s ruling on a collateral issue “‘is substantially the same as a final judgment in an independent proceeding’ [citation], in that it leaves the court no further action to take on ‘a matter which … is severable from the general subject of the litigation’ [citation], an appeal will lie from that collateral order even though other matters in the case remain to be determined.” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 561 .) An interlocutory order is appealable under the collateral order doctrine when it is “collateral to the main issue, dispositive of the rights of the parti

2023Under the collateral order doctrine, an interlocutory order or judgment is appealable despite the absence of a final judgment “when there has been a final determination of a collateral matter which is distinct and severable from the general subject of the litigation.” (In re Marriage of Laursen & Fogarty (1988) 197 Cal.App.3d 1082, 1086, fn. 4 ; see also In re Marriage of Garcia (2017) 13 Cal.App.5th 1334, 1344 .) In marriage dissolution cases, courts have long recognized that “disputes over division of marital property, custody of minor children and spousal support are essentially collateral

2009History has borne out the wisdom of this analysis, for since then ‘[t]he California Supreme Court has consistently limited the collateral order doctrine to situations where a trial judge orders either payment of money or the performance of some act.’ (Samuel v. Stevedoring Services (1994) 24 Cal.App.4th 414, 418 [ 29 Cal.Rptr.2d 420 ], citing Bauguess v. Paine[, supra,] 22 Cal.3d 626, 634, fn. 3 ; In re Marriage of Skelley, supra, 18 Cal.3d 365, 368 ; Sarracino v. Superior Court (1974) 13 Cal.3d 1, 9 [ 118 Cal.Rptr. 21 , 529 P.2d 53 ].) H] We conclude that judicially compelled payment of money

1996History has borne out the wisdom of this analysis, for since then “[t]he California Supreme Court has consistently limited the collateral order doctrine to situations where a trial judge orders either payment of money or the performance of some act.” (Samuel v. Stevedoring Services (1994) 24 Cal.App.4th 414, 418 [ 29 Cal.Rptr.2d 420 ], citing Bauguess v. Paine (1978) 22 Cal.3d 626, 634, fn. 3 [ 150 Cal.Rptr. 461 , 586 P.2d 942 ]; In re Marriage of Shelley, supra, 18 Cal.3d 365, 368 ; Sarracino v. Superior Court (1974) 13 Cal.3d 1, 9 [ 118 Cal.Rptr. 21 , 529 P.2d 53 ].) We conclude that judicia

2022The court further stated, “Separately and alternatively, however, even assuming an order taxing costs is no longer appealable as an order after judgment, we believe it is appealable under the collateral order doctrine.” (Krikorian, supra, 193 Cal.App.4th at p. 1083 .) “The effect of an order denying a motion to tax costs, in whole or in part, is that the moving party must pay the costs allowed.” (Id. at p. 1084.) The court declined to “decide whether an order taxing all costs, and thus awarding zero, would be immediately appealable.” (Id. at p. 1084, fn. 3.) Krikorian is consistent with Lachka

2013(Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 ; see In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 [“[w]hen a court renders an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing payment of money or performance of an act, direct appeal may be taken”]; Krikorian Premiere Theatres, LLC v. Westminister Central, LLC (2011) 193 Cal.App.4th 1075, 1078 .) The collateral order doctrine has been applied to permit an appeal from an order awarding attorney fees and costs, for example, after issuance of a nonap

2024(See City of Colton, supra, 206 Cal.App.4th at p. 782 .) Similarly, the court in Baharian-Mehr, although not relying on the collateral order doctrine, stated that when “the issue of whether the anti-SLAPP motion should have been granted is properly before the appellate court, it would be absurd to defer the issue of attorney fees until a future date, resulting in the probable waste of judicial resources.

2023(Compare Doe v. Luster (2006) 145 Cal.App.4th 139, 145-150 [holding there is no statutory basis for an immediate appeal of a separate order awarding or denying fees under section 425.16, subdivision (c)] with City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 781-782 [holding an order awarding or denying fees under section 425.16, subdivision (c) is directly appealable under the collateral order exception to the one 5 Conroy’s only contention on appeal regarding the trial court’s order declining to strike causes of action two through four is that those causes of action should have been s

2023The order directs the payment of money by the appellant or the performance of an act by or against appellant. [Citations.]” (Marsh v. Mountain Zephyr, Inc., supra, 43 Cal.App.4th at pp. 297-298.) In short, the collateral order doctrine allows appeal of “an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing payment of money or performance of an act.” (In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 .) Here, the trial court’s order on attorney fees and costs meets all the requirements of the collatera

2023The order directs the payment of money by the appellant or the performance of an act by or against appellant. [Citations.]” (Marsh v. Mountain Zephyr, Inc., supra, 43 Cal.App.4th at pp. 297-298.) In short, the collateral order doctrine allows appeal of “an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing payment of money or performance of an act.” (In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 .) Here, the trial court’s order on attorney fees and costs meets all the requirements of the collatera

2022(Marsh v. Mountain Zephyr (1996) 43 Cal.App.4th 289 , 297– 298, citing Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 ; accord, Reddish, at p. 278; (Koshak v. Malek (2011) 200 Cal.App.4th 1540, 1545 (Koshak).) In other words, under the collateral order rule, “ ‘an appeal will lie from [a] collateral order even though other matters in the case remain to be determined,’ but that exception applies only ‘[w]here the trial court’s ruling on a collateral issue “is substantially the same as a final judgment in an independent proceeding” [citation], in that it leaves the court no further action to take

2021Even if it is technically interlocutory, an order dispositive of the rights of the parties in relation to a 15 collateral matter, or directing payment of money or performance of an act, may be subject to direct appeal.” (In re Marriage of Eben-King & King (2000) 80 Cal.App.4th 92, 115-116 .) For example, in Koshak, a court found a civil defendant guilty of contempt for violating a receivership order and ordered him to pay $1.7 million in restitution to the receivership. ( Koshak, supra, 200 Cal.App.4th at pp. 1543-1544.) The reviewing court held that the order was appealable under the collater

2023(Compare Doe v. Luster (2006) 145 Cal.App.4th 139, 145-150 [holding there is no statutory basis for an immediate appeal of a separate order awarding or denying fees under section 425.16, subdivision (c)] with City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 781-782 [holding an order awarding or denying fees under section 425.16, subdivision (c) is directly appealable under the collateral order exception to the one 5 Conroy’s only contention on appeal regarding the trial court’s order declining to strike causes of action two through four is that those causes of action should have been s

2021Proc., § 1294, subd. (a); Nelsen v. Legacy Partners Residential, Inc. (2012) 207 Cal.App.4th 1115, 1121 [“Orders granting motions to compel arbitration are generally not immediately appealable.”]; Hernandez v. Ross Stores, Inc. (2016) 7 Cal.App.5th 171, 176 [“The denial of a motion to compel arbitration is an appealable order.”]; Cf. Doe v. Luster (2006) 145 Cal.App.4th 139, 150 [a separate order granting or denying attorney’s fees in connection with an anti-SLAPP motion (§§ 425.16, et seq.) is itself not separately appealable].) Appellant has not articulated any policy reason why the collater

2011After a judgment is entered, [the appellant] may appeal . . . from the interlocutory determination . . . taxing costs. [Citation.]” (Ibid., fn. omitted.) In a footnote, the court also held that the order taxing costs was not appealable under the collateral order doctrine: “The collateral order doctrine only applies to orders to pay money. [Citation.] The amount remaining due by defendant after the order partially taxing the sums sought in the postappeal cost memorandum is immediately collectible by plaintiff. [Citation.] Plaintiff’s contention is he is entitled to more money; that is not an or

2008(Lachkar v. Lachkar (1986) 182 Cal.App.3d 641, 645, fn. 1 [ 227 Cal.Rptr. 501 ] (Lachkar); cf. Barnes v. Litton Systems, Inc. (1994) 28 Cal.App.4th 681, 685 [ 33 Cal.Rptr.2d 562 ] [order taxing costs is not sufficiently final to be appealable by party seeking additional costs and appeal can be taken after judgment is entered].) The Marcus and MBNA courts, however, did not cite the collateral order doctrine; rather, these courts noted that the respective orders vacating an arbitration award (Marcus) and denying a petition to confirm an arbitration award (MBNA) were “final” and that the prevaili

2009History has borne out the wisdom of this analysis, for since then ‘[t]he California Supreme Court has consistently limited the collateral order doctrine to situations where a trial judge orders either payment of money or the performance of some act.’ (Samuel v. Stevedoring Services (1994) 24 Cal.App.4th 414, 418 [ 29 Cal.Rptr.2d 420 ], citing Bauguess v. Paine[, supra,] 22 Cal.3d 626, 634, fn. 3 ; In re Marriage of Skelley, supra, 18 Cal.3d 365, 368 ; Sarracino v. Superior Court (1974) 13 Cal.3d 1, 9 [ 118 Cal.Rptr. 21 , 529 P.2d 53 ].) H] We conclude that judicially compelled payment of money

2009History has borne out the wisdom of this analysis, for since then ‘[t]he California Supreme Court has consistently limited the collateral order doctrine to situations where a trial judge orders either payment of money or the performance of some act.’ (Samuel v. Stevedoring Services (1994) 24 Cal.App.4th 414, 418 [ 29 Cal.Rptr.2d 420 ], citing Bauguess v. Paine[, supra,] 22 Cal.3d 626, 634, fn. 3 ; In re Marriage of Skelley, supra, 18 Cal.3d 365, 368 ; Sarracino v. Superior Court (1974) 13 Cal.3d 1, 9 [ 118 Cal.Rptr. 21 , 529 P.2d 53 ].) H] We conclude that judicially compelled payment of money

2025(Griset v. Fair Political Practices Com. (2001) 3 Undesignated statutory references are to the Code of Civil Procedure. 5 25 Cal.4th 688, 696 .) The baseline principle of appealability is the one final judgment rule, which “prohibits review of intermediate rulings by appeal until final resolution of the case.” (Id. at p. 697.) Appellants assert two exceptions to the one final judgment rule as alternative grounds for appealability: (1) the collateral order doctrine and (2) the statutory exception for orders on injunctions.

2021DISCUSSION I Appealability The parties dispute whether the court’s order is appealable. “ ‘The existence of an appealable judgment [or order] is a jurisdictional prerequisite to an appeal.’ ” (In re Marriage of Grimes & Mou (2020) 45 Cal.App.5th 406 , 418 (Grimes & Mou); accord, Griset v. Fair Political Practices Com. (2001) 14 25 Cal.4th 688, 696 .) Manickam contends the court’s order is appealable under the collateral order doctrine.

2023(Olson v. Cory (1983) 35 Cal.3d 390, 398 .) “ ‘To qualify as appealable under the collateral order doctrine, the interlocutory order must (1) be a final determination (2) of a collateral matter (3) and direct the payment of money or performance of an act.’ ” (Sanchez v. Westlake Services, LLC (2022) 73 Cal.App.5th 1100 , 1107–1108 [collecting cases]; see Dr. V Productions, Inc. v. Rey (2021) 68 Cal.App.5th 793 , 797 [“[t]he modern formulation” of the collateral order doctrine “makes no mention of an order denying the payment of money or refusing to require performance of an act”]; Sese v. Well

2021(Jennings v. Marralle (1994) 8 Cal.4th 121, 126 (Jennings) [reviewing court must raise issue of appellate jurisdiction “on its own initiative” whenever a doubt exists]; Olson v. Cory (1983) 35 Cal.3d 390, 398 [“since the question of appealability goes to our jurisdiction, we are dutybound to consider it on our own motion”].) For this reason, shortly after receiving this appeal and prior to the filing of the record on appeal, we issued an order, advising and directing the parties in part as follows: “A split of authority exists as to whether an order awarding or denying attorney[ ] fees under s

2023(Olson v. Cory (1983) 35 Cal.3d 390, 398 .) “ ‘To qualify as appealable under the collateral order doctrine, the interlocutory order must (1) be a final determination (2) of a collateral matter (3) and direct the payment of money or performance of an act.’ ” (Sanchez v. Westlake Services, LLC (2022) 73 Cal.App.5th 1100 , 1107–1108 [collecting cases]; see Dr. V Productions, Inc. v. Rey (2021) 68 Cal.App.5th 793 , 797 [“[t]he modern formulation” of the collateral order doctrine “makes no mention of an order denying the payment of money or refusing to require performance of an act”]; Sese v. Well

2023We agree that, in view of the unique terms of this settlement, which does not require plaintiffs to file a dismissal prior to payment of fees and costs despite the parties’ final resolution of issues in the trial court, we may properly review the challenged order under the collateral order doctrine. “[When] there is no final judgment . . . , the issue is whether the order from which the appeal has been taken fits within an exception to the one final judgment rule codified in . . . section 904.1.” (Sese v. Wells Fargo Bank N.A. (2016) 2 Cal.App.5th 710 , 714- 715.) 6 “A recognized exception to

2013The only plausible exception applicable here is what we will refer to as the ‘collateral order’ class of appealable orders: ‘When a court renders an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing [the] payment of money or performance of an act, direct appeal may be taken.’ [Citation.]” (Conservatorship of Rich (1996) 46 Cal.App.4th 1233, 1235 , original italics.) 3 Messih v. Lee Drug, Inc. (1985) 174 Cal.App.3d 312 applied the collateral-order rule to orders granting an attorney’s motion to be relie

2013(Krikorian, supra, 193 Cal.App.4th at p. 1083 .) The collateral order exception allows a direct appeal from “an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing [the] payment of money or performance of an act.” (Rich, supra, 46 Cal.App.4th at p. 1235 , italics omitted.) This exception applies when (1) the judgment or order is final as to the collateral matter; and (2) the subject of the judgment or order is, in fact, collateral to the subject of the litigation.

2025Bank v. Superior Court (1993) 4 19 Cal.App.4th 1256 , 1261–1262 [denying writ petition to the extent it challenged allocation of referee fees].) We also reject the notion that this order can be appealed pursuant to the collateral order doctrine. “[T]he collateral order doctrine, as the California Supreme Court has historically described it, allows an appeal to be taken ‘[w]hen a court renders an interlocutory order collateral to the main issue, dispositive of the rights of the parties in relation to the collateral matter, and directing payment of money or performance of an act.’” (Longobardo v

2014Such a determination is substantially the same as a final judgment in an independent proceeding. [Citations.]” (In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 [ 134 Cal.Rptr. 197 , 556 P.2d 297 ]; see Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [ 199 P.2d 668 ] [an otherwise interlocutory order is directly appealable “if the order is a final judgment against a party in a collateral proceeding growing out of the action”]; Fish v. Fish (1932) 216 Cal. 14, 16 [ 13 P2d 375 ] [provision of the order in setting compensation for receiver’s attorney was “in effect a final judgment against a part

2022Such a determination is substantially the same as a final judgment in an independent proceeding.” (In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 ; see Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [an otherwise interlocutory order is directly appealable “if the order is a final judgment against a party in a collateral proceeding growing out of the action”]; see also Hanna v. Mercedes-Benz USA, LLC (2019) 36 Cal.App.5th 493, 506 .) “To qualify as appealable under the collateral order doctrine, the interlocutory order must (1) be a final determination (2) of a collateral matter (3) and dire

2022Such a determination is substantially the same as a final judgment in an independent proceeding.” (In re Marriage of Skelley (1976) 18 Cal.3d 365, 368 ; see Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [an otherwise interlocutory order is directly appealable “if the order is a final judgment against a party in a collateral proceeding growing out of the action”]; see also Hanna v. Mercedes-Benz USA, LLC (2019) 36 Cal.App.5th 493, 506 .) “To qualify as appealable under the collateral order doctrine, the interlocutory order must (1) be a final determination (2) of a collateral matter (3) and dire

2023(Olson v. Cory (1983) 35 Cal.3d 390, 398 .) “ ‘To qualify as appealable under the collateral order doctrine, the interlocutory order must (1) be a final determination (2) of a collateral matter (3) and direct the payment of money or performance of an act.’ ” (Sanchez v. Westlake Services, LLC (2022) 73 Cal.App.5th 1100 , 1107–1108 [collecting cases]; see Dr. V Productions, Inc. v. Rey (2021) 68 Cal.App.5th 793 , 797 [“[t]he modern formulation” of the collateral order doctrine “makes no mention of an order denying the payment of money or refusing to require performance of an act”]; Sese v. Well

2023The Muller court also found it significant that the federal collateral order doctrine differed from California’s on this point, and that the federal rule “has functioned in the federal courts without these limitations since its inception in 1949.” ( Muller, supra, at p. 903 .) In subsequent cases, California courts describing the collateral order doctrine have largely continued to recite all three elements, often without acknowledging the split in authority or taking a side.

2023(See In re Marriage of Freitas, supra, 209 Cal.App.4th at pp. 1074-1075.) Although the trial court here reserved jurisdiction, we conclude the interests advanced by the collateral order doctrine are best served by deeming the order awarding temporary spousal support to be appealable.

2017(See Sullivan , supra , 15 Cal.4th at p. 304 , 63 Cal.Rptr.2d 74 , 935 P.2d 781 ; Olson , supra , 35 Cal.3d at p. 399 , 197 Cal.Rptr. 843 , 673 P.2d 720 ; Corona , supra , 172 Cal.App.4th at p. 1217 , 92 Cal.Rptr.3d 17 .) *1344 However, "a necessary exception to the one final judgment rule" is the collateral order doctrine, pursuant to which an interlocutory order is appealable if it finally determines the rights of the parties in relation to that matter, leaving no further judicial acts to be done in regard thereto, and directs the payment of money or performance of an act. ( Skelley , supra

2009Thus, in the frequently cited opinion in Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [ 199 P.2d 668 ], the court, after noting the existence of the collateral order doctrine emphatically went on to state: “It is not sufficient that the order determine finally for the purposes of further proceedings in the trial court some distinct issue in the case; it must direct the payment of money by appellant or the performance of an act by or against him.” Seven years later, in Meehan v. Hopps (1955) 45 Cal.2d 213 [ 288 P.2d 267 ] (Meehan), the court disregarded the limitations on the collateral order d

2009Thus, in the frequently cited opinion in Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [ 199 P.2d 668 ], the court, after noting the existence of the collateral order doctrine emphatically went on to state: “It is not sufficient that the order determine finally for the purposes of further proceedings in the trial court some distinct issue in the case; it must direct the payment of money by appellant or the performance of an act by or against him.” Seven years later, in Meehan v. Hopps (1955) 45 Cal.2d 213 [ 288 P.2d 267 ] (Meehan), the court disregarded the limitations on the collateral order d

2025Its purpose is to maintain the living conditions and standards of the parties [and their children] as closely as possible to the status quo, pending trial and the division of the assets and obligations of the parties.’” ( Gruen, supra, at p. 637 ; In re Marriage of Askmo (2000) 85 Cal.App.4th 1032, 1038 .) A temporary support order is operative from the time of pronouncement and is directly appealable as a final order under the collateral order doctrine. ( Gruen, supra, 191 Cal.App.4th at pp. 637–638; Last v. Superior Court (2023) 94 Cal.App.5th 30 , 43– 44.) It may later “be modified or termi

2025Its purpose is to maintain the living conditions and standards of the parties [and their children] as closely as possible to the status quo, pending trial and the division of the assets and obligations of the parties.’” ( Gruen, supra, at p. 637 ; In re Marriage of Askmo (2000) 85 Cal.App.4th 1032, 1038 .) A temporary support order is operative from the time of pronouncement and is directly appealable as a final order under the collateral order doctrine. ( Gruen, supra, 191 Cal.App.4th at pp. 637–638; Last v. Superior Court (2023) 94 Cal.App.5th 30 , 43– 44.) It may later “be modified or termi