Filing An Appeal from Multiple Judgments
In General Electric Credit Corp. v. Aetna Casualty & Surety Co., 437 Pa. 463, 263 A.2d 448 (1970), our Supreme Court reviewed the propriety of filing one appeal from multiple judgments.
There, the plaintiff corporation filed an action against seven insurance companies to recover damages sustained in a fire.
A jury returned a verdict in favor of the plaintiff corporation against five of the seven defendants; two defendants were found not liable.
After post-trial motions were denied, separate judgments were entered as to each defendant.
However, the plaintiff corporation filed one notice of appeal as to all seven defendants.
Relevant for current purposes, the Court considered the appeal from two orders denying post-trial relief against the exonerated defendants.
Although the Court ultimately disposed of the appeal on the merits, it recognized the established principles that "taking one appeal from several judgments is not acceptable practice and is discouraged" and that "a single appeal is incapable of bringing on for review more than one final order, judgment or decree ...." Id. at 468-70, 263 A.2d at 452.
This is by no means an inflexible rule. a court may refrain from quashing an appeal in the interests of judicial economy. Id.
Nevertheless, a court will quash an appeal where review will not provide a meaningful remedy. Id.
This Court, relying on General Electric, holds "the practice of filing one appeal from multiple orders is strongly disapproved and in the future, the Court will quash single appeals from multiple orders unless otherwise dictated by compelling circumstances." Croft v. Unemployment Comp. Bd. of Review, 662 A.2d 24, 28 (Pa. Cmwlth. 1995);
See also Praskac v. Unemployment Comp. Bd. of Review, 683 A.2d 329, 333 (Pa. Cmwlth. 1996).