What is the effect of the one judgment rule on cross-complaint?

The result of the operation of the one judgment rule may appear harsh and warrants explanation. First, the reason for the rule is that an 'action normally proceeds to a single judgment on the issues raised by the complaint and cross-complaint and there is no need nor right to a separate final judgment on the cross-complaint.' (6 Witkin, Part I (1971) Cal. Procedure 2d Ed., 45, pp. 4058--4059.) Second, the appealability of the orders sustaining the demurrer and dismissing the cross-defendants is merely suspended pending final determination of the rights of the parties in respect to the underlying complaint. Thus, it is 'no more harsh than any case where a party is forced to stand trial because of an erroneous ruling of a trial court.' (Sjoberg v. Hastorf, Supra.) Finally, the fragmentation of an action during the pleading and proof stages on the trial level could delay the expeditious handling on the trial level and clog up the appellate courts by piecemeal appeals. The efficient and orderly administration of justice allows the complaint to proceed to final determination on the trial level, unhampered, unimpeded and uninterrupted by possible protracted delays from appeals on a cross-complaint, with the appellate courts receiving decisions from the trial courts which have finally disposed of the whole subject matter of the litigation for one final review on appeal.

Can Jurisdiction Be Conferred by Stipulation, Consent or Waiver?