M.G. v. S.J., 1205 WDA 2015

Father filed a petition to modify child support on March 12, 2015; a hearing was scheduled for April 7, 2015.
On April 2, 2015, Mother filed a motion to designate the matter "complex" and the court signed an order continuing the April 7 hearing and rescheduling a complex hearing for July 31, 2015.
Counsel for Mother misfiled the April 2 order, so Father appeared on April 7 expecting the simple hearing; Mother did not appear.
The hearing officer on April 7 issued a recommendation continuing the modification petition for a two-hour complex hearing on July 31 and left the April 2 order in effect; the trial court adopted that recommendation.
Father filed exceptions arguing he was entitled to modification by default due to Mother’s absence; the trial court dismissed his exceptions on July 10, 2015.
Father appealed two interlocutory orders: (1) dismissal of his exceptions (July 10, 2015), and (2) the July 9, 2015 order continuing the complex hearing, holding certain discovery motions moot, and denying attorney’s fees for discovery noncompliance.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (Mother/Trial Court)	Held
Whether the trial court erred by dismissing Father’s exceptions to the hearing officer’s April 7 recommendation and failing to grant modification by default due to Mother’s nonappearance	Father argued Mother’s absence on April 7 entitled him to a default modification and the court should have granted relief rather than continue the matter	Court maintained the April 2 order designating the case complex and rescheduling the hearing; the April 7 continuation was proper	Appeal quashed as interlocutory because the July 10 order did not decide the merits and merely continued the matter
Whether the July 9, 2015 order continuing the complex hearing, ruling certain discovery motions moot, and denying fees was appealable	Father contended the continuance and rulings were improper and sought review	Trial court treated discovery rulings as moot in light of continuance and declined fees pending resolution	Appeal quashed as interlocutory; continuance and discovery rulings are not final or immediately appealable

Angelichio v. Myers, 110 A.3d 1046 (Pa. Super. 2015) (general rule: appeals lie only from final orders)
West v. West, 446 A.2d 1342 (Pa. Super. 1982) (finality requires disposing of all claims and parties)
Rodgers v. Rodgers, 423 A.2d 4 (Pa. Super. 1980) (order granting continuance is not a final appealable order)
Pennsy Supply, Inc. v. Mumma, 921 A.2d 1184 (Pa. Super. 2007) (interlocutory appeals must be quashed absent an applicable exception)
Lasco v. Lasco, 446 A.2d 963 (Pa. Super. 1982) (quashing appeal where lower court postponed final determination)
Smith v. Philadelphia Gas Works, 740 A.2d 1200 (Pa. Super. 1999) (discovery orders are interlocutory and not appealable until final judgment)