McCall v. Commonwealth
In McCall v. Commonwealth, 20 Va. App. 348, 457 S.E.2d 389 (1995), the Court held that, under the pre-1992 version of Code 16.1-107, a court has no duty to bifurcate support arrearage judgments from other issues to determine whether a party must post a bond. Id. at 349, 457 S.E.2d at 390.
The Court noted that when McCall appealed from a juvenile court judgment, he "did not specify or indicate in any way that he was appealing only the civil contempt citation and not the determination as to the amount of his support arrearage." Id. at 350, 457 S.E.2d at 391.
The Court also noted that McCall initially asserted the limited nature of his appeal only in this Court. See id. at 350, 457 S.E.2d at 390.
Thus, The Court affirmed the ruling dismissing McCall's appeal because he did not bifurcate the issues.