I. INTRODUCTION
In this domestic relations appeal, David de Haan (“father”) argues the lower court erred in (1) holding the decision of a judge pro tempore was final instead of pendente lite; (2) granting Lynn Holmbeck de Haan (“mother”) primary custody of the parties’ children; and (3) declining to enjoin mother from relocating with the children. 1 We hold that since the appealed order did not resolve all issues, it represents an interlocutory order over which we have limited subject matter jurisdiction. We further hold that since the order left several main objects of the divorce suit unresolved, the order did not adjudicate “the principles of a cause” within the meaning of Code § 17.1-405(4) and, therefore, we lack subject matter jurisdiction to hear the appeal. Accordingly, we dismiss the appeal without prejudice.
*432 II. BACKGROUND
The parties married in 1994. They have three surviving minor daughters. Another daughter died as an infant. The parties separated in March 2008. At that time, father was a stay at home parent and a retired major in the Army. Mother was a lieutenant colonel on active duty in the Air Force Reserve.
Mother filed a complaint seeking divorce in the Circuit Court of Fairfax County. In addition to the divorce, mother’s complaint sought custody of the children, child support, equitable distribution, exclusive possession of the marital home and contribution for its maintenance, an injunction against wasting or dissipating marital assets, and attorney fees. Father soon filed his answer to the complaint and a counterclaim for divorce, essentially seeking the same relief as mother. Both parties filed motions for pendente lite relief, and father filed a motion to enjoin mother from relocating with the children to the Norfolk/Virginia Beach area.
The parties agreed to employ a judge pro tempore to adjudicate certain areas more rapidly than they would otherwise be heard under the circuit court scheduling system. The circuit court agreed to the designation of a judge pro tempore and entered an order appointing one on May 12,. 2008. The order provided the judge pro tempore with authority to adjudicate nine areas:
i. Enforcement of Pre-Marital Agreement of January 20, 1994
ii. Custody of the parties’ three children
iii. Child support
iv. Designation of parenting time between Plaintiff and Defendant
v. Injunction from removal of the parties’ three children from the County of Fairfax, Virginia, by the Plaintiff
vi. Injunction from dissipating or wasting marital assets or increasing debts for which the other party would be liable
vii. Exclusive use of the marital home
*433 viii. Exclusive use of the Nissan Quest mini-van
ix. Award of attorney’s fees, expenses, and costs[.]
The order contained no limit on the authority over these areas. Rather, the order stated that the “judge pro tempore is hereby appointed and vested with the same power and authority and is hereby charged with the same duties as to the cause in and as to which he is appointed as if he were a regularly elected and qualified judge of this Court.” Brian Hirsch was the person appointed judge pro tempore.
The judge pro tempore held an ore terms hearing on the relevant issues from May 15-16, 2008, during which he received extensive evidence. Given our disposition of this case, most of it lacks relevance to this opinion. However, we note that while mother worked at the Pentagon at the time of the hearing, she had received orders to transfer to a position in Norfolk, Virginia. Mother’s testimony suggested that after accepting the Norfolk position, she had no choice but to move. She testified: “Whether or not I’m awarded custody, I have to move to Norfolk. I’ve taken an oath and I’ve accepted the orders.” While working in Norfolk, mother planned to reside in nearby Virginia Beach. These facts have relevance to this opinion because of father’s desire to prohibit mother from relocating there with the children.
The judge pro tempore issued a letter opinion on May 21, 2008. The opinion noted the nine areas of jurisdiction the parties asked him to resolve. It also stated “[t]he parties filed cross motions for pendente lite relief, essentially asking for the above [nine areas of] relief.”
Concerning custody, the judge pro tempore considered each of the statutory factors and awarded the parties joint legal custody, with mother having primary physical custody of the children during the school year and shared custody during the summer. The letter opinion contained a detailed custody arrangement, which was obviously intended to be final on the issue. 2 When deciding custody, the judge pro tempore as *434 sumed mother’s relocation as inevitable, specifically noting it was from “Mother’s impending move that this hearing arose.” The judge pro tempore again indicated the inevitability of mother’s move in another portion of his opinion. In spite of this inevitability, the judge pro tempore granted mother permission to relocate with the children to the Norfolk/Virginia Beach area, denying father’s request for an injunction prohibiting the move.
Regarding child support, the judge pro tempore accepted evidence presented by mother on father’s earning potential and imputed father with income “after September 30, 2008,” with the amount of income depending on where father chose to reside. If father remained in the Northern Virginia area it would be $75,000, or if he moved to be closer to the children it would be $65,000. The letter opinion called for child support to be “recalculated in September 2008.”
Other relevant provisions of the letter opinion involve the disposition of marital property. The judge pro tempore enjoined the parties from “dissipating or wasting marital assets,” but expressly declined “to classify the parties’ assets as marital, separate and hybrid.” The judge pro tempore asked the parties to consult each other on items mother could remove from the marital house. However, the opinion held that “[t]o the extent the parties are unable to agree upon a temporary division of property ... this issue shall be decided at the parties’ equitable distribution hearing or by written agreement.” The opinion also stated that “removal of such furnishings by the Mother or the retention of same by the Father shall be without prejudice to a final disposition of the parties’ furnishings.”
The judge pro tempore concluded by requesting mother’s counsel to prepare an order consistent with the letter opinion.
*435 Asserting the hearing and letter opinion of the judge pro tempore involved only a pendente lite disposition on custody, father’s counsel requested the circuit court to set a date for a final hearing on custody. A Fairfax County Circuit Court judge denied this request on a calendar control form dated June 3, 2008. The order stated: “Defendant’s Request for hearing date on custody. It’s opposed. This has been decided.” That judge also wrote: “Appeal from final order of Judge Pro Tern is to the Court of Appeals.”
The next relevant order was entered on July 14, 2008. The order set a final hearing on equitable distribution, spousal support, and child support for April 8, 2009. However, at oral argument, this Court learned this hearing was stayed pending the appeal.
The judge pro tempore’s letter opinion was reduced to an order on August 22, 2008, entitled “FINAL ORDER BY JUDGE PRO TEMPORE ” (“the August 22 order”). The order essentially granted the relief provided by the letter opinion verbatim, with only minor variation. One of those variations to note is that the order called for mother to submit evidence of her child care costs at her new home. 3 This was to facilitate the recalculation of child support in September 2008 called for by the letter opinion and incorporated into the order.
Father now appeals from the August 22 order.
III. ANALYSIS
It is axiomatic that before considering the merits of a case, we must have subject matter jurisdiction.
Comcast of Chesterfield County, Inc. v. Bd. of Supervisors of Chesterfield County,
“The Court of Appeals of Virginia is a court of limited jurisdiction.”
Canova Elec. Contracting, Inc. v. LMI Ins. Co.,
Our jurisdiction over domestic relations disputes comes from Code § 17.1-405. In relevant part, that section provides us jurisdiction over:
3. Any final judgment, order, or decree of a circuit court involving:
c. Custody;
d. Spousal or child support;
e. The control or disposition of a child;
******
4. Any interlocutory decree or order entered in any of the cases listed in this section (i) granting, dissolving, or denying an injunction or (ii) adjudicating the principles of a cause.
Code § 17.1-405. Thus, aside from eligible interlocutory decrees under subsection (4), the Code permits us to review only “final” orders.
As defined by the Virginia Supreme Court, a final order “ ‘is one which disposes of the whole subject, gives all the relief contemplated, provides with reasonable complete
*437
ness for giving effect to the sentence, and leaves nothing to be done in the cause save to superintend ministerially the execution of the order.’ ”
James v. James,
Orders retaining “jurisdiction to reconsider the judgment or to address other matters still pending in the action” lack finality.
Super Fresh Food Mkts. of Va. v. Ruffin,
The fact that an order is labeled as final is not dispositive on its finality; the order must, in fact, be final. Thus, in
Estate of Hackler v. Hackler,
Application of these principles reveals that in spite of its title as a final order, the August 22 order lacked finality.
Estate of Hackler,
This Court may only hear interlocutory appeals under the jurisdiction provided by Code § 17.1-405(4). As mentioned above, the appealed order must grant, dissolve, or deny an injunction or adjudicate “the principles of a cause.” Id.
The Virginia Supreme Court defined the phrase “adjudicating the principles of a cause” in
Lewis v. Lewis,
“[I]t must mean that the rules or methods by which the rights of the parties are to be finally worked out have been so far determined that it is only necessary to apply these rules or methods to the facts of the case in order to ascertain the relative rights of the parties with regard to the subject matter of the suit.”
Id.
at 526,
An interlocutory order “adjudicating the principles of a cause” “must ‘determine the rights of the parties’ and ‘would of necessity affect the final order in the case.’ ”
Erikson v. Erikson,
Significant policy interests counsel against frequent interlocutory appeals and, therefore, finding an order adjudicates “the principles of a cause.” Even in the antebellum era, Virginia courts recognized the need “to prevent the delay and expense of unnecessary and reiterated appeals” that could result from broad interlocutory appellate jurisdiction.
4
Cocke’s Adm’r v. Gilpin,
The reasons for generally requiring final judgments before appeal remain forceful today. As this Court has noted, the general rule prohibiting interlocutory appeal “ ‘preserves the [trial] court’s independence and protects parties from the harassment of separate appeals of individual rulings.’ ”
5
Lan
*441
caster,
Simply stated, interlocutory appeals often result in inefficiency and unnecessary delay and expense. “By their nature, interlocutory appeals are disruptive, time-consuming, and expensive.”
Waste Mgmt. Holdings, Inc. v. Mowbray,
This does not mean, of course, that parties may not appeal any interlocutory orders to this Court, for the General Assembly has plainly provided that orders “adjudicating the principles of a cause” may be appealed. Code § 17.1-405(4). Such cases present the opposite scenario of the cost/benefit analysis normally weighing against interlocutory review, for in appeal-able interlocutory orders “unnecessary expenses and litigation would be avoided by permitting appeals.”
Ryan’s Adm’r v. McLeod,
The analysis in
Higginbotham v. Brown,
Similarly, our Supreme Court later remarked on how it would regularly “refuse an appeal from an interlocutory de
*443
cree until the case is more fully developed on its merits. Such a refusal does not bar a subsequent application when the case has been so developed, and especially after a final decree has been entered.”
Mathieson Alkali Works v. Va. Banner Coal Corp.,
Based on this precedent and especially when evaluated in light of the strong policy considerations against frequent interlocutory appeal, we conclude that where a trial court in a divorce suit enters an order resolving only some of the main objects of the suit, such an order normally does not adjudicate “the principles of a cause.” 7 To hold otherwise would permit divorce litigants to appeal each order of the trial court adjudicating the divorce, custody, equitable distribution, child support, or spousal support. 8 The resulting inefficiency would compel this Court to repeatedly entertain the same suit and significantly delay the progress of the case at the trial level as the case halted pending the appeal. 9 Normal, standard cases would receive interlocutory review, along with the delay and expense accompanying it. We do not believe the General Assembly intended these consequences. Only rarely does interlocutory review save time and money. 10
*444 These problems would particularly manifest themselves in cases arising from Fairfax County such as this one, for since the trial court in that jurisdiction apparently bifurcates every divorce case, every case could generate multiple appeals. The disruption of the trial process and expense to the parties would prove severe. This Court would become a body closely scrutinizing trial court decisions instead of a body reviewing the entire record after mature consideration of the issues by the trial court. The volume of our caseload would also exponentially increase, further delaying cases of such intimate importance to the parties.
Indeed, the facts of this case illustrate the woes that would occur if orders such as the one here could receive immediate appeal. The judge pro tempore issued his order on August 22, 2008. The parties now receive a decision approximately twelve months later, with no other progress having occurred in the case. The trial court must still adjudicate the divorce and equitable distribution, after which the parties may return to this Court and wait another twelve months. We think such inefficiencies unwise. Had this appeal not occurred, the trial *445 court could have adjudicated the remaining issues and the parties could have then taken an appeal to this Court, where we could review the entire record and correct any errors warranting reversal.
Along this reasoning, we hold father’s first and second assignments of error do not adjudicate “the principles of a cause” and are, therefore, not eligible for interlocutory appeal.
11
Father first argues the Fairfax County Circuit Court judge erred by declaring in a calendar control form that the custody decision contained in the letter opinion of the judge
pro tempore
was final rather than
pendente lite.
Yet the calendar control order’s statement that father must appeal did not make final that which plainly lacked finality for purposes of appeal. At most, the order held the trial court would not receive further evidence concerning custody. Moreover, the judge
pro tempore
was not bound to follow the Fairfax County Circuit Court judge’s interpretation of the letter opinion when entering the August 22 order. The Code vested him with the same powers as a regular trial judge in the areas he considered, Code § 17.1-110, as did the order appointing him. Nothing in the record suggests the judge
pro tempore
believed the calendar control form bound him. In the absence of contrary evidence, we presume judges know the law and correctly apply it.
Wilson v. Commonwealth,
*446 Finally, while father’s third assignment of error concerning the judge pro tempore’s decision to deny an injunction prohibiting mother from relocating with the children to the Norfolk/Virginia Beach area may appear to fall -within our jurisdiction in Code § 17.1-405(4), which permits interlocutory appeals from orders denying injunctions, the relocation issue is, in fact, moot since the judge pro tempore presumed mother’s relocation was inevitable and that she there then lived, when deciding custody. This was appropriate since mother testified regarding her pending military transfer: “Whether or not I’m awarded custody, I have to move to Norfolk. I’ve taken an oath and I’ve accepted the orders.” Since the judge pro tempore found mother residing in Virginia Beach should receive custody, a separate decision on relocation was unnecessary. 12 Thus, the relocation issue falls within the custody decision, which is not presently appealable.
We remain mindful that trial courts have a strong interest in resolving particular issues within litigation to control their dockets and that the judge pro tempore’s designation of his order as “final” and the Fairfax County Circuit Court judge’s statement that appeal from a final order goes to this Court served those ends. Certainly the law gives trial courts significant latitude in managing their dockets. See Code § 8.01-4 (authorizing trial courts to adopt local rules and docket control methods). Yet that discretion has its limits.
*447 Within time limitations established by statute or jurisprudence, circuit courts may devise procedures to resolve issues within a cause of action, accommodating their dockets, to be heard on various days or times, or by various judges within their circuits. A circuit court may by order decree that no further evidence will be heard concerning such an issue resolved. But a circuit court may not designate the resolution of an issue within a pending cause of action as final. A circuit court may not by such designation expand the appellate jurisdiction of the Court of Appeals beyond that set forth in Code § 17.1-405 and our jurisprudence governing that jurisdiction. To designate that which is not final as final places counsel and/or parties in an untenable position: Do I appeal now, or when the final order in the cause of action is entered? 13 And, further, in appeals of right, such erroneous designation requires this Court to consider, as here, matters prematurely before us.
For the foregoing reasons, we hold we lack subject matter jurisdiction to consider this appeal and, therefore, dismiss it without prejudice.
Dismissed.
Notes
. On brief, father claimed the judge pro tempore also erred by imputing income to him for child support purposes and requiring him to make pendente lite payments on the marital home without contribution from mother. However, at oral argument, father’s counsel withdrew these arguments.
. Statements from the hearing clearly reveal the parties' intention that the judge pro tempore's custody decision be final on that issue. At one *434 point, the judge pro tempore sought to confirm the hearing was only for pendente lite purposes, “not a final hearing.” Mother’s counsel responded: “It is on the custody portion, Your Honor.” Father’s counsel made no challenge to this assertion.
. The letter opinion simply stated that “daycare costs in Norfolk are uncertain at this point and it is premature to calculate same.”
. As our Supreme Court later remarked, the appellate process represents an "expensive remedy.”
Kendrick v. Whitney,
. The United States Supreme Court has also spoken of the danger frequent interlocutory appeals could pose for a trial court's independence where factual determinations are important, stating that review could make the appellate body more a supervisor of the case than a review tribunal.
Coopers & Lybrand v. Livesay,
. The public policy favoring appeal from final judgments over interlocutory review forms part of the general policy supporting an expedient end to litigation. Along this reasoning, our Supreme Court has stated that "[ljitigation is a serious and harassing matter, and the right to know when it is ended is a valuable right.”
Avery v. County Sch. Bd. of Brunswick County,
. We merely hold that under circumstances such as those present here an order is not immediately appealable. We do not speculate on other circumstances.
. Orders on discrete issues may be final where they constitute the only issues in the litigation.
. After this Court obtains jurisdiction because of an appeal, the trial court loses jurisdiction, except to enforce pre-existing orders.
Frazer v. Frazer,
. We do not hold parties may only appeal final orders, for our Supreme Court has clearly held interlocutory orders may adjudicate "the principles of a cause” and thereby be appealable.
Butler v. Hayes,
. As our Supreme Court once held: "Until a final decree, or one adjudicating the principles of the cause, is properly brought before this court, it is without power to exert its appellate jurisdiction.”
Johnston
v.
Johnston,
. We distinguish Judd v.
Judd,
. The issue of whether parties may immediately appeal the custody order entered under the bifurcated divorce trial system employed in Fairfax County has apparently resulted in much speculation. In response to a question at oral argument about this, mother's counsel stated: "I think that's a question that every Fairfax County lawyer would like to know the answer to."