In Commonwealth v. Walker, 185 A.3d 969 (Pa. 2018), the Pennsylvania Supreme Court came down hard on a question of appellate procedure that arises fairly frequently: An appellant filing a single notice of appeal that purports to appeal from multiple, separate appealable orders.  Walker involved a quite blatant example of the practice—a single notice from orders in four cases with “four different docket numbers,”—but its reasoning extends to all notices of appeal from different appealable orders.

The Supreme Court affirmed that, where a notice of appeal encompasses multiple orders, the appeal must be quashed. That’s right, quashed. Previously, on the rare occasions (three times in a century) where the court mentioned the issue, it only noted that the practice of including multiple orders in the same notice of appeal was “disfavored,” as in Clark v. Clark, 191 A.2d 417, 418 n.2 (Pa. 1963), (“Even though in this instance we render a decision on the merits, taking one appeal from several judgments and orders is not acceptable practice and is discouraged.”).

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