In the Interest of: R.N. & F.N., a Minor, In the Interest of: R.N. & F.N., a Minor No. 1725 MDA 2016

Two separate September 16, 2016 orders reassigning a caseworker in Luzerne County dependency cases were appealed by CYS.
Appeal was filed from two separate orders on two different dockets; Rule 341 requires separate notices from separate orders.
Court treated the appeal as improper due to lack of separate notices and quashed the appeal.
Trial court had previously entered an agreement designating Hazleton office supervision and transferring files to Hazleton with Wilkes-Barre staff clearance.
CYS sought collateral-order review of the interlocutory assignment orders, arguing the orders were collateral and irreparably impaired by postponement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the September 16, 2016 orders are appealable collateral orders.	CYS argues the orders are collateral and review is necessary.	Court held collateral-order criteria not met.	Appeal quashed; collateral-order requirements not satisfied.

Rae v. Pennsylvania Funeral Directors Association, 977 A.2d 1121 (Pa. 2009) (collateral-order review requires all three elements)
Spanier v. Freeh, 95 A.3d 342 (Pa. Super. 2014) (rights must be deeply rooted in public policy)
Graziani v. Randolph, 856 A.2d 1212 (Pa. Super. 2004) (third collateral-order element requires irreparable loss of review)
Jacksonian v. Temple University Health System Foundation, 862 A.2d 1275 (Pa. Super. 2004) (collateral-order doctrine elements must be satisfied)
General Electric Credit Corp. v. Aetna Casualty & Surety Co., 263 A.2d 448 (Pa. 1970) (separation across multiple orders discouraged)
Egenrieder v. Ohio Casualty Group, 581 A.2d 937 (Pa. Super. 1990) (separate appeals required when multiple orders issued)