Appealability History Lesson

 2/5's Justice Kim gives us a little history lesson in dismissing this appeal:

Plaintiff contends that we should consider the merits of her appeal notwithstanding the absence of a signed dismissal order, citing Simmons v. Superior Court (1959) 52 Cal.2d 373 (Simmons). We disagree. Simmons is distinguishable as it does not discuss Code of Civil Procedure section 581d. Moreover, at the time Simmons was decided, the applicable version of Code of Civil Procedure section 581d did not require that a dismissal order be signed by the trial court for it to be considered an appealable judgment. (Compare Stats. 1959, ch. 346, p. 2269, § 1 [“All dismissals ordered by the court shall be entered upon the minutes thereof . . . and such orders when so entered or filed shall constitute judgments and be effective for all purposes”], with Stats. 1963, ch. 875, p. 2123, § 1 [“All dismissals ordered by the court shall be in the form of a written order signed by the court and filed in the action . . . and such orders when so filed shall constitute judgments and be effective for all purposes”].)