one final judgment rule in California

2026(See, e.g., In re Baycol Cases I & II (Baycol) 51 Cal.4th 751 , 760–762 [explaining that in class actions, the “death knell doctrine” renders appealable an order terminating class claims but allowing individual claims to continue]; Wong v. Dong (2025) 112 Cal.App.5th 109 , 114–115 [orders granting or denying an anti-SLAPP motion to strike fall within an exception to the “one final judgment rule”].) As City and Skanska note, another exception to the one final judgment rule exists “in multiparty actions where a judgment or order resolves all of the issues as to one of the parties, in which case

2025(In re Baycol Cases I & II, supra, 51 Cal.4th at pp. 754, 756.) This prohibition is in keeping with the premise of the one final judgment rule ‘ “ ‘that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ ” [Citations.]’ (Id. at p. 756.)” (Kaiser Foundation, supra, 13 Cal.App.5th at p. 1138.) Thus, “an appeal cannot be taken from a judgment that fails to complete the disposition of all the causes of action between the parties even if the causes of action disposed

2026“The existence of an appealable judgment [or order] is a jurisdictional prerequisite to an appeal.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) And “[a] single order or judgment can be in part appealable and in part nonappealable.” (See Six4Three, LLC v. Facebook, Inc. (2020) 49 Cal.App.5th 109 , 113.) “The right to appeal is wholly statutory.” (Dana Point Safe Harbor Collective v. Superior Court (2010) 51 Cal.4th 1, 5 (Dana Point).) Section 904.1 “lists appealable judgments and orders.” (Ibid.) First and foremost, section 904.1 codifies the one final judgment rule by stating that an ap

2026(Morehart v. County of Santa Barbara (1994) 7 Cal.4th 725, 741 (Morehart).) Flats and Simon argue the one final judgment rule requires us to deny City and Skanka’s motion.

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

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

2025(Kurwa, supra, 57 Cal.4th at p. 1106 [judgment that disposes of fewer than all claims is not appealable where parties agree to dismiss remaining claims without prejudice but waive operation of statute of limitations to allow those claims to be revived on remand after appeal]; see also Gutkin v. University of Southern California (2002) 101 Cal.App.4th 967, 975 [voluntary dismissal of remaining claims without prejudice “could not have the legal effect of a final judgment, and could not serve to expedite an appeal” from interim orders].) “To permit this kind of manipulation of appellate jurisdict

2025(Kurwa, supra, 57 Cal.4th at p. 1106 [judgment that disposes of fewer than all claims is not appealable where parties agree to dismiss remaining claims without prejudice but waive operation of statute of limitations to allow those claims to be revived on remand after appeal]; see also Gutkin v. University of Southern California (2002) 101 Cal.App.4th 967, 975 [voluntary dismissal of remaining claims without prejudice “could not have the legal effect of a final judgment, and could not serve to expedite an appeal” from interim orders].) “To permit this kind of manipulation of appellate jurisdict

2025App. & Writs Ch. 2-B, § 2.177.2 [“immediate appeal will lie as a matter of right from a final order or judgment in a bifurcated family law proceeding regarding child custody or visitation rights (i.e., there is no need for the superior court to certify the ruling for immediate appeal or for the court of appeal to grant a ‘motion to appeal’ ”)].) In addition, one exception to the one final judgment rule is the “so-called collateral order doctrine.” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 561 (Lester).) Under that doctrine, “[w]here the trial court’s ruling on a collateral issue ‘is substa

2006(Sjoberg v. Hastorf (1948) 33 Cal.2d 116, 119 [ 199 P.2d 668 ].) The “collateral judgment” or “collateral order” rule remains a viable exception to the one final judgment rule.

2025(Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688, 696 .) The baseline principle is the one final judgment rule, which “prohibits review of intermediate rulings by appeal until final resolution of the case.” (Id. at p. 697.) “A family law court may bifurcate trial on one or more issues, including division of property or child custody, if resolution of the bifurcated issue is likely to simplify the determination of the other issues. [Citations.] Although an order on a bifurcated issue is not separately appealable, the family law court may certify in its order that there is probable

2025DISCUSSION A. Motion to dismiss The one final judgment rule is “a fundamental principle of appellate practice that prohibits review of intermediate rulings by appeal until final resolution of the case.” (Griset v. Fair Political Practices Commission (2001) 25 Cal.4th 688, 697 .) “ ‘The theory is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ ” (Id., quoting 9 Witkin, Cal. Procedure (4th ed. 1997) Appeal, § 58, p. 113.) Code of Civil Procedure section 90

2022(Reddish v. Westamerica Bank (2021) 68 Cal.App.5th 275 , 277.) The overall objective of the one final judgment rule is to avoid the cost and oppression of “piecemeal disposition and multiple appeals.” (Kinoshita v. Horio (1986) 186 Cal.App.3d 959 , 966–967.) Judgments confirming arbitration awards are subject to the one final judgment rule.

2021(Kinoshita v. Horio (1986) 186 Cal.App.3d 959, 967 [the policy underlying the one final judgment rule is served when a later trial court ruling may obviate the need for an interlocutory appeal].) B.

2022(Rao v. Campo (1991) 233 Cal.App.3d 1557, 1564-1565 [“[U]nder the one final judgment rule, interlocutory or interim orders are not appealable, but are only ‘reviewable on appeal’ from the final judgment.”]; Contreras-Velzazquez v. Family Health Centers of San Diego, Inc. (2021) 62 Cal.App.5th 88 , 101-102 [where reviewing court affirms trial court’s grant of new trial, “ ‘ “the effect is that there is no longer a final judgment,” ’ ” and reviewing court will not decide issues raised on cross-appeal].) Given our determination in the main appeal that the judgment must be reversed and the matter

2012Welfare and Institutions Code former section 366.26, subdivision (k) stated, “An order by the court directing that a hearing pursuant to this section be held is not an appealable order, but may be the subject of review by extraordinary writ.” (Stats. 1991, ch. 820, § 5, pp. 3648, 3652.) Our Supreme Court analyzed whether this language barred raising the appropriateness of an order setting a parental termination rights hearing in a postjudgment appeal: “The phrase, ‘not an appealable order,’ has long been applied to interlocutory orders that are not immediately appealable, but are subject to re

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

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

2016However, ‘“[generally an order is not a final order until the final judgment in the matter has been entered. ‘Unless otherwise provided by statute, an appeal lies only from a judgment that terminates the proceedings in the lower court by *715 completely disposing of the matter in controversy [citations].’ (Henneberque v. City of Culver City (1985) 172 Cal.App.3d 837, 841 [ 218 Cal.Rptr. 704 ].) [¶] [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 [Code of Civil Proce

2016However, ‘“[generally an order is not a final order until the final judgment in the matter has been entered. ‘Unless otherwise provided by statute, an appeal lies only from a judgment that terminates the proceedings in the lower court by *715 completely disposing of the matter in controversy [citations].’ (Henneberque v. City of Culver City (1985) 172 Cal.App.3d 837, 841 [ 218 Cal.Rptr. 704 ].) [¶] [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 [Code of Civil Proce

2025(Cortez, supra, 15 Cal.App.5th at p. 9 [concluding “the death knell exception to the one final judgment rule does not apply when a PAGA claim remains pending in the trial court following termination of the class claims”]; Nguyen v. Applied Medical Resources Corp. (2016) 4 Cal.App.5th 232 , 243–244 [same]; Young v. RemX, Inc. (2016) 2 Cal.App.5th 630, 635 (Young) [same]; Munoz v. Chipotle Mexican Grill, Inc. (2015) 238 Cal.App.4th 291 , 310–311 (Munoz) [“Denial of class certification where the PAGA claims remain in the trial court would not have the ‘legal effect’ of a final judgment . . . .”].

2022Equipment Co. (2017) 15 Cal.App.5th 1, 9 [“We … hold the death knell exception to the one final judgment rule does not apply when a PAGA claim remains pending in the trial court following termination of the class claims.”].) An appealable order is a “jurisdictional prerequisite to an appeal.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) Moreover, this case does not present “ ‘unusual circumstances’ ” such that we may treat Plaintiffs’ premature appeal as a petition for 1 This is a companion appeal to Mendez-Villegas v. Duarte (Oct. 20, 2022, F082174) (nonpub. opn.), which concerns the tr

2023Proc., § 904.1, subd. (a)(1) [an appeal may be taken from “a judgment, except an interlocutory judgment”]; see Kurwa v. Kislinger (2013) 57 Cal.4th 1097, 1104 [“ ‘claims that are dismissed without prejudice are no less final for purposes of the one final judgment rule than are adjudicated claims’ ”], quoting Abatti v. Imperial Irrigation Dist. (2012) 205 Cal.App.4th 650, 665 ; Davis v. Southern California Edison Co. (2015) 236 Cal.App.4th 619, 622, fn. 3 [a dismissal without prejudice is appealable if it is made by the court without agreement by the parties as to future litigation or waiver of

2014Kurwa quoted with approval the decision in Abatti v. Imperial Irrigation Dist. (2012) 205 Cal.App.4th 650 (Abatti), where the court held: “Dismissal of some counts without prejudice, by itself, does not deprive a judgment of appealability, as ‘claims that are dismissed without prejudice are no less final for purposes of the one final judgment rule than are adjudicated claims . . . .’ ( Abatti, supra, at p. 665 .) But where the parties have reached an agreement that assures the potential for future litigation of the dismissed claims, the judgment ‘lacks sufficient finality to be appealable purs

2026“The existence of an appealable judgment [or order] is a jurisdictional prerequisite to an appeal.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) And “[a] single order or judgment can be in part appealable and in part nonappealable.” (See Six4Three, LLC v. Facebook, Inc. (2020) 49 Cal.App.5th 109 , 113.) “The right to appeal is wholly statutory.” (Dana Point Safe Harbor Collective v. Superior Court (2010) 51 Cal.4th 1, 5 (Dana Point).) Section 904.1 “lists appealable judgments and orders.” (Ibid.) First and foremost, section 904.1 codifies the one final judgment rule by stating that an ap

2025(Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695 , 698–699 [citations].)” (Kaiser Foundation Health Plan, Inc. v. Superior Court (2017) 13 Cal.App.5th 1125, 1138 (Kaiser Foundation).) “Under the one final judgment rule, interlocutory judgments generally are not appealable.

2025(Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695 , 698–699 [citations].)” (Kaiser Foundation Health Plan, Inc. v. Superior Court (2017) 13 Cal.App.5th 1125, 1138 (Kaiser Foundation).) “Under the one final judgment rule, interlocutory judgments generally are not appealable.

2019However, the death knell doctrine is an exception to the one final judgment rule. ( Baycol , at p. 757, 122 Cal.Rptr.3d 153 , 248 P.3d 681 .) It allows an immediate appeal of an order that entirely terminates class claims while allowing individual claims to proceed. ( Id. at pp. 757, 759, 122 Cal.Rptr.3d 153 , 248 P.3d 681 .) Because such an order "effectively [rings] the death knell for the class claims," it is essentially "a final judgment on those claims." ( Id. at p. 757, 122 Cal.Rptr.3d 153 , 248 P.3d 681 ; see Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695 , 699, 63 Cal.Rptr. 724 , 433 P.2d

2025(Cortez, supra, 15 Cal.App.5th at p. 9 [concluding “the death knell exception to the one final judgment rule does not apply when a PAGA claim remains pending in the trial court following termination of the class claims”]; Nguyen v. Applied Medical Resources Corp. (2016) 4 Cal.App.5th 232 , 243–244 [same]; Young v. RemX, Inc. (2016) 2 Cal.App.5th 630, 635 (Young) [same]; Munoz v. Chipotle Mexican Grill, Inc. (2015) 238 Cal.App.4th 291 , 310–311 (Munoz) [“Denial of class certification where the PAGA claims remain in the trial court would not have the ‘legal effect’ of a final judgment . . . .”].

2019However, the death knell doctrine is an exception to the one final judgment rule. ( Baycol , at p. 757, 122 Cal.Rptr.3d 153 , 248 P.3d 681 .) It allows an immediate appeal of an order that entirely terminates class claims while allowing individual claims to proceed. ( Id. at pp. 757, 759, 122 Cal.Rptr.3d 153 , 248 P.3d 681 .) Because such an order "effectively [rings] the death knell for the class claims," it is essentially "a final judgment on those claims." ( Id. at p. 757, 122 Cal.Rptr.3d 153 , 248 P.3d 681 ; see Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695 , 699, 63 Cal.Rptr. 724 , 433 P.2d

2023It qualifies as a “final determination” because “ ‘further 6 Under the one final judgment rule, “ ‘an appeal may be taken only from the final judgment in an entire action.’ ” (Molien v. Kaiser Foundation Hospitals (1980) 27 Cal.3d 916, 921 , quoting Tenhet v. Boswell (1976) 18 Cal.3d 150, 153 .) “ ‘The theory [behind the rule] is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ [Citations.]” (Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688,

2023It qualifies as a “final determination” because “ ‘further 6 Under the one final judgment rule, “ ‘an appeal may be taken only from the final judgment in an entire action.’ ” (Molien v. Kaiser Foundation Hospitals (1980) 27 Cal.3d 916, 921 , quoting Tenhet v. Boswell (1976) 18 Cal.3d 150, 153 .) “ ‘The theory [behind the rule] is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ [Citations.]” (Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688,

2025Prejudgment orders generally “‘are not appealable but are “reviewable on appeal” from the final judgment.’” (Doran v. Magan (1999) 76 Cal.App.4th 1287, 1292-1293 (Doran).) Section 904.1 sets forth exceptions to the one final judgment rule and identifies prejudgment orders that are appealable.

2024Interlocutory orders generally “‘are not appealable, but are only “reviewable on appeal” from the final judgment.’” (Doran v. Magan (1999) 76 Cal.App.4th 1287, 1292-1293 (Doran).) Section 904.1 sets forth exceptions to the one final judgment rule and identifies interlocutory orders that are appealable.

2024(Griset, supra, 25 Cal.4th at p. 697 .) 5 Because we conclude the MSA Order is not appealable, we need not address the timeliness of the appeal. 8 Rocketship relies on the rule that “ ‘in a case involving multiple parties, a judgment is final and appealable when it leaves no issues to be determined as to one party.’ [Citations.]” (Heshejin v. Rostami (2020) 54 Cal.App.5th 984 , 991; Baycol Cases, supra, 51 Cal.4th at p. 759 .) However, this exception to the one final judgment rule applies only where “the interests of the otherwise uninvolved party are separate and distinct from the interests o

2014(Cf. First Security Bank of Cal. v. Paquet (2002) 98 Cal.App.4th 468, 474 [noting in derivative shareholder action and other contexts that “[w]hen a party brings an action in multiple capacities, a judgment determining that party’s rights in one capacity may be final even though the action is still pending on a claim brought in a different capacity”].) Promark analogizes to scenarios in which the one final judgment rule for appeal “does not apply when the case involves multiple parties and a judgment is entered which leaves no issue to be determined as to one party.” (Justus v. Atchison (1977)

2021(City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 780 (Singletary).) Subdivision (a)(1) “codifies the common law one final judgment rule.” (Baycol Cases, at p. 756.) In addition, subdivisions (a)(2)-(a)(13) “list[ ] various specific additional appealable orders that stand as exceptions to the general rule.” (Baycol Cases, at p. 756, fn. 3.)6 “ ‘[E]xceptions to the one final judgment rule should not be allowed unless clearly mandated.’ ” (Id. at p. 757.) A prejudgment order denying a motion for attorney fees and costs (like the August 2019 Order here) is not appealable under any statute

2016Van may appeal from the trial court's June 29 order granting attorney fees under the anti-SLAPP statute pursuant to the collateral order exception to the one final judgment rule Although an order awarding attorney fees pursuant to the anti-SLAPP statute is not statutorily appealable pursuant to section 904.1 (see City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 781 (City of Colton), such an order may be appealable pursuant to the collateral order exception to the one final judgment rule.

2026“The existence of an appealable judgment [or order] is a jurisdictional prerequisite to an appeal.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) And “[a] single order or judgment can be in part appealable and in part nonappealable.” (See Six4Three, LLC v. Facebook, Inc. (2020) 49 Cal.App.5th 109 , 113.) “The right to appeal is wholly statutory.” (Dana Point Safe Harbor Collective v. Superior Court (2010) 51 Cal.4th 1, 5 (Dana Point).) Section 904.1 “lists appealable judgments and orders.” (Ibid.) First and foremost, section 904.1 codifies the one final judgment rule by stating that an ap

2026A reviewing court must raise the issue on its own initiative whenever a doubt exists as to whether the trial court has entered a final judgment or other order or judgment made appealable by . . . section 904.1.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) “There are three categories of appealable judgments or orders: (1) final judgments as determined by case law, (2) orders and interlocutory judgments made expressly appealable by statute, and (3) certain judgments and orders that, although they do not dispose of all issues in the case are considered ‘final’ for appeal purposes and are e

2024A. Applicable Law “In most cases, appeal is only allowed from the final judgment.” (Aleman v. AirTouch Cellular (2012) 209 Cal.App.4th 556, 585 (Aleman), citing § 904.1.) “The one final judgment rule is ‘a fundamental principle of appellate practice.’ ” (In re Baycol Cases I & II (2011) 51 Cal.4th 751, 756 (Baycol).) “ ‘ “The theory [behind the rule] is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.” ’ ” (Ibid.) Adherence to the rule furthers judicial ef

2019BACKGROUND A. The Death Knell Doctrine The one final judgment rule is a fundamental rule of appellate practice: " ' "an appeal may be taken only from the final judgment in an entire action." ' " ( In re Baycol Cases I & II (2011) 51 Cal.4th 751 , 756, 122 Cal.Rptr.3d 153 , 248 P.3d 681 ; § 904.1.) An exception to the one final judgment rule is the death knell doctrine, which is unique to class actions. ( Baycol Cases , at p. 757, 122 Cal.Rptr.3d 153 , 248 P.3d 681 .) "This doctrine provides that an order which allows a plaintiff to pursue individual claims but prevents the plaintiff from maint

2025(Cortez, supra, 15 Cal.App.5th at p. 9 [concluding “the death knell exception to the one final judgment rule does not apply when a PAGA claim remains pending in the trial court following termination of the class claims”]; Nguyen v. Applied Medical Resources Corp. (2016) 4 Cal.App.5th 232 , 243–244 [same]; Young v. RemX, Inc. (2016) 2 Cal.App.5th 630, 635 (Young) [same]; Munoz v. Chipotle Mexican Grill, Inc. (2015) 238 Cal.App.4th 291 , 310–311 (Munoz) [“Denial of class certification where the PAGA claims remain in the trial court would not have the ‘legal effect’ of a final judgment . . . .”].

2021Proc., § 1294; Nguyen v. Applied Medical Resources Corp. (2016) 4 Cal.App.5th 232, 242 (Nguyen).) Tovar contends the court’s order is appealable under the death knell doctrine, “a judicially created exception to the one final judgment rule, [which] treats an order that dismisses class claims while allowing individual claims to survive as an appealable order.” (Cortez v. Doty Bros.

2025App. & Writs Ch. 2-B, § 2.177.2 [“immediate appeal will lie as a matter of right from a final order or judgment in a bifurcated family law proceeding regarding child custody or visitation rights (i.e., there is no need for the superior court to certify the ruling for immediate appeal or for the court of appeal to grant a ‘motion to appeal’ ”)].) In addition, one exception to the one final judgment rule is the “so-called collateral order doctrine.” (Lester v. Lennane (2000) 84 Cal.App.4th 536, 561 (Lester).) Under that doctrine, “[w]here the trial court’s ruling on a collateral issue ‘is substa

2013Where 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, supra, 84 Cal.App.4th at p. 561 ; see also 9 Witkin, Cal. Procedure, supra, Appeal, § 99, p. 162 [“A necessary exception to the one final judgment rule is recognized where there is a final de

2025(In re Baycol Cases I & II, supra, 51 Cal.4th at pp. 754, 756.) This prohibition is in keeping with the premise of the one final judgment rule ‘ “ ‘that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ ” [Citations.]’ (Id. at p. 756.)” (Kaiser Foundation, supra, 13 Cal.App.5th at p. 1138.) Thus, “an appeal cannot be taken from a judgment that fails to complete the disposition of all the causes of action between the parties even if the causes of action disposed

2015(Paquet, supra, 98 Cal.App.4th at p. 473 .) Moreover, the one final judgment rule applies separately to each capacity in which a party brings an action or is named as a defendant.

2016(Id. at pp. 743-745.) Morehart disapproved of an exception to the one final judgment rule recognized in Schonfeld v. City of Vallejo (1975) 50 Cal.App.3d 401 , and progeny, which allowed an appeal from a judgment that left some causes of action unresolved, when those counts were tried separately or severed for trial.

2013Proc., § 904.1, subd. (a)), and not yet final, as to any parties between whom another cause of action remains pending.” (Morehart, supra, 7 Cal.4th at p. 741 .) The theory of the rule is that “ ‘piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ (9 Witkin, Cal. Procedure (4th ed. 1997) Appeal, § 58, p. 113; [citations].)” (Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688, 697 [ 107 Cal.Rptr.2d 149 , 23 P.3d 43 ].) Morehart disapproved an exception t

2026A reviewing court must raise the issue on its own initiative whenever a doubt exists as to whether the trial court has entered a final judgment or other order or judgment made appealable by . . . section 904.1.” (Jennings v. Marralle (1994) 8 Cal.4th 121, 126 .) “There are three categories of appealable judgments or orders: (1) final judgments as determined by case law, (2) orders and interlocutory judgments made expressly appealable by statute, and (3) certain judgments and orders that, although they do not dispose of all issues in the case are considered ‘final’ for appeal purposes and are e

2016(People v. Mazurette (2001) 24 Cal.4th 789, 792 .) “There are three categories of appealable judgments or orders: (1) final judgments as determined by case law, (2) orders and interlocutory judgments made expressly appealable by statute, and (3) certain judgments and orders that, although they do not dispose of all the issues in the case are considered ‘final’ for appeal purposes and are exceptions to the one-final-judgment rule.” (Conservatorship of Rich (1996) 46 Cal.App.4th 1233, 1235 .) Here, there is no final judgment as no action was ever allowed or filed.

2023It qualifies as a “final determination” because “ ‘further 6 Under the one final judgment rule, “ ‘an appeal may be taken only from the final judgment in an entire action.’ ” (Molien v. Kaiser Foundation Hospitals (1980) 27 Cal.3d 916, 921 , quoting Tenhet v. Boswell (1976) 18 Cal.3d 150, 153 .) “ ‘The theory [behind the rule] is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ [Citations.]” (Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688,

2023It qualifies as a “final determination” because “ ‘further 6 Under the one final judgment rule, “ ‘an appeal may be taken only from the final judgment in an entire action.’ ” (Molien v. Kaiser Foundation Hospitals (1980) 27 Cal.3d 916, 921 , quoting Tenhet v. Boswell (1976) 18 Cal.3d 150, 153 .) “ ‘The theory [behind the rule] is that piecemeal disposition and multiple appeals in a single action would be oppressive and costly, and that a review of intermediate rulings should await the final disposition of the case.’ [Citations.]” (Griset v. Fair Political Practices Com. (2001) 25 Cal.4th 688,