Calhoun v. Vallejo City Unified School Dist

In Calhoun v. Vallejo City Unified School Dist. (1993) 20 Cal.App.4th 39, the trial court made two rulings during a hearing, one relating to venue and one imposing sanctions. The appellant filed a notice stating that he appealed from the imposition of sanctions. (20 Cal.App.4th at p. 41.) He then proceeded to attack the ruling on venue in his brief. The appellate court wrote, "there was not even an attempt to appeal the venue ruling. The notice of appeal specifies only the portion of the order imposing sanctions. Because the two rulings are not interdependent, the purported partial appeal from the sanction ruling precludes review of the venue ruling." ( Id. at p. 42.)