In the case of de Haan v. de Haan, the Virginia Court of Appeals, in a published opinion, dismissed a father's appeal where the father tried to appeal a custody and visitation order issued by a judge pro tempore. The Virginia Court of Appeals determined that it lacked subject matter jurisdiction to hear the appeal because the judge pro tempore's order constituted an interlocutory appeal. The judge pro tempore's order did not adjudicate the "principles of the cause". In other words, the judge pro tempore's order was not final because it didn't decide all of the other issues in the case such as divorce and equitable distribution.
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