Justice HECHT
delivered the opinion of the Court,
in which Chief Justice PHILLIPS, Justice OWEN, Justice ABBOTT, and Justice O’NEILL joined.
In these two consolidated cases we revisit the persistent problem of determining when a judgment rendered without a conventional trial on the merits is final for purposes of appeal. We consider only cases in which one final and appealable judgment can be rendered and not cases, like some probate and receivership proceedings, in which multiple judgments final for purposes of appeal can be rendered on certain discrete issues.1 And we consider a judgment’s finality only for purposes of appeal and not for other purposes, such as issue and claim preclusion.2 In Mafrige v. Ross,3 we held that a summary judgment is final if it contains language purporting to dispose of all claims and parties. We gave as one example of such language what we have called a “Mother Hubbard” clause 4—a recitation that all relief not expressly granted is denied.5 Since then, the routine inclusion of this general statement in otherwise plainly interlocutory orders and its ambiguity in many contexts have rendered it inapt for determining finality when there has not been a conventional trial. We no longer believe that a Mother Hubbard clause in an order or in a judgment issued without a full trial can be taken to indicate finality. We therefore hold that in cases in which only one final and appealable judgment can be rendered, a judgment issued without a conventional trial is final for purposes of appeal if and only if either it actually disposes of all claims and parties then before the court, regardless of its language, or it states with unmistakable clarity that it is a final judg[193]*193ment as to all claims and all parties. In the two cases before us, the court of appeals concluded that judgments that do not meet this test were final and dismissed the appeals as having been untimely perfected.6 We reverse and remand for consideration of the merits of the appeals.
I
Lehmann v. Har-Con Corp.
Douglas and Virginia Lehmann sued the University of St. Thomas and Har-Con Corp. in the district court in Harris County to recover damages for injuries Douglas suffered in a construction accident. The University cross-claimed against Har-Con for indemnity. The Lehmanns settled with Har-Con and executed a release, agreeing in part to indemnify Har-Con against certain claims which had been or could be asserted by or through them. Virginia then filed an amended petition on behalf of her minor son against both defendants, claiming damages for loss of parental consortium because of his father’s injuries. In response, Har-Con filed a counterclaim against Virginia and a third-party petition against Douglas, seeking indemnity from them under the terms of their prior release.
The Lehmanns and Har-Con all moved for summary judgment on Har-Con’s indemnity claims. The district court denied the Lehmanns’ motion and granted Har-Con’s motion. The court’s order granting Har Con’s motion stated in full:
[caption]
ORDER
On this 12 day of March, 1998 came on to be considered the Motion for Summary Judgment of HAR-CON CORPORATION. After considering the motion, the response, the summary judgment evidence and the argument of counsel, the Court is of the opinion that the motion should be in all things granted. It is therefore,
ORDERED, ADJUDGED AND DECREED that the Motion for Summary Judgment by HAR-CON CORPORATION be and it is hereby GRANTED.
All relief not expressly granted herein is denied.
Signed this the 12 day of March, 1998
s/-
JUDGE PRESIDING
[s/ Attorneys for Har-Con Corporation]
The order did not reference Virginia’s claims on behalf of her son against Har-Con, although it would appear that Har Con’s summary judgment on its indemnity claim would effectively bar recovery for Virginia’s son. The order also did not reference Virginia’s son’s claims against the University, which would not appear to be affected by Har-Con’s summary judgment. The order contained a “Mother Hubbard” clause stating that “[a]ll relief not expressly granted herein is denied.”
The district clerk advised the Lehmanns by postcard that an interlocutory summary judgment order had issued. The record does not reflect whether the parties received a copy of the actual order after it was signed. The Lehmanns tell us that the practice of the district clerk in Harris County is not to send copies of orders to the parties but to give parties notice by postcard when orders are signed. The notice does not completely describe the content of the order.
The Lehmanns appear to have believed that the summary judgment order was interlocutory because they moved to sever it and Har-Con’s claims into a separate action, ostensibly to make the summary judgment final. The court granted the motion to sever on the twenty-fifth day after the summary judgment order was signed. Twenty-eight days after the sev-[194]*194eranee order was signed, the Lehmanns noticed their appeal from the summary judgment order.
If the summary judgment was not final until the severance order was signed, then the Lehmanns’ appeal was timely. But the court of appeals held that the summary judgment order was final when it issued because of the Mother Hubbard clause and that the order was not modified by the severance so as to restart the time for perfecting appeal.7 Because the Leh-manns did not perfect appeal within thirty days of the signing of the order as prescribed by the rules of appellate procedure,8 the court dismissed the appeal for want of jurisdiction. In holding that the summary judgment order was final, the court followed our decision in Mafrige, although the court expressed concerns that the inclusion of a Mother Hubbard clause in an otherwise plainly interlocutory order should not make the order final.
We granted the Lehmanns’ petition for review and consolidated it for argument and decision with Harris v. Harbour Title Co.9
Harris v. Harbour Title Co.
Melvin and Helena Harris sued five defendants — Greenfield Financial Corp. and Larry J. Greenfield (“the Greenfield defendants”), Tim Rice and Rice Development, Inc. (“the Rice defendants”), and Harbour Title Co. — in the district court in Harris County on breach-of-contract and tort claims arising from a conveyance of real property. The court granted an interlocutory default judgment against Tim Rice on liability only, leaving for later a determination of the damages to be assessed against him. The Harrises nonsuited their claims against the Greenfield defendants. The fifth defendant, Harbour Title Co., moved for summary judgment, which the court granted with the following order:
Order Granting Harbour Title Company’s Motion for Summary Judgment
On August 28, 1998, came on to be heard the Motion for Summary Judgment of one of the defendants, Harbour Title Company, and the Court having considered the Motion, together with any response, and the supplemental briefing filed by the parties to date is of the opinion that said Motion is with merit and should be granted. It is therefore
ORDERED that defendant Harbour Title Company’s Motion for Summary Judgment is in all things granted; it is further
ORDERED that the Plaintiffs, Melvin G. Harris and Helena M. Harris take nothing as to any of their claims against Harbour Title Company.
All relief requested and not herein granted is denied.
SIGNED this 15 day of October 1998.
APPROVED AND ENTRY REQUESTED:
[s/ Attorneys for Harbour Title Company]
Although the order did not reference the Harrises’ pending claims against the Rice defendants, it nevertheless contained a Mother Hubbard clause stating that “[a]ll relief requested and not herein granted is denied.”
The Harrises assert that they received notice of the order by a postcard that described the order as an interlocutory summary judgment, but the postcard is not in our record. The record does not reflect whether the parties obtained a copy of the order after it was signed. It appears that the district clerk followed her usual procedure of notifying the parties by [195]*195postcard in lieu of providing copies of the order.
The district court apparently did not consider the summary judgment order to be final; forty-six days after it was signed, the court generated a form order setting the case for trial the next year. The Har-rises, too, appear to have believed the summary judgment to be interlocutory; two weeks after the order issued setting the case for trial, the Harrises obtained what was captioned a “Final Default Judgment” against the Rice defendants. Twenty-five days later the Harrises noticed them appeal from Harbour Title’s summary judgment.
If Harbour Title’s summary judgment did not dispose of the Harrises’ claims against the Rice defendants, and the default judgment against those defendants was the final order in the case, then the Harrises’ appeal was timely. But following Mafrige, as it had done in Lehmann, the court of appeals concluded that the summary judgment order was final and therefore dismissed the appeal as not having been timely perfected. We granted the Harrises’ petition for review and consolidated it with Lehmann for argument and decision.10
II
A
Though its origins are obscure and its rationale has varied over time,11 the general rule, with a few mostly statutory exceptions, is that an appeal may be taken only from a final judgment.12 A judgment is final for purposes of appeal if it disposes of all pending parties and claims in the record, except as necessary to carry out the decree.13 (An order that does not dispose of all pending parties and claims may also be final for purposes of appeal in some instances, such as orders that resolve certain discrete issues in some probate 14 and receiverships15 cases, but we exclude those cases from consideration here. Nor do we consider when a judgment may be final for purposes other than appeal, such as claim and issue preclusion.16) Because the law does not require that a final judgment be in any particular form, whether a judicial decree is a final judgment must be determined from its language and the record in the case. Since timely perfecting appeal (as well as filing certain post-judgment motions and requests) hangs on a party’s making this determination correctly, certainty is crucial.
From the beginning, however, certainty in determining whether a judgment is final has proved elusive. What has vexed courts in this State and elsewhere is this; must a final judgment dispose of all parties and claims specifically, or may it do so by general language or even by inference? If a specific disposition of each party and [196]*196claim is strictly required, a judgment apparently intended by the parties and the trial court to be final and appealable may not be. An appeal from such a judgment must be dismissed or at least abated, resulting in delay and a waste of the courts’ and the parties’ resources. More importantly, if a judgment intended to be final did not meet the strict requirements, then the case would remain open, allowing the possibility of further proceedings and appeal years later. On the other hand, if a judgment may dispose of all parties and claims by general language or inference, a party or trial court may think that a judgment is interlocutory, only to be told later by the appellate court after the time for appeal has passed that the judgment was final. A party who is uncertain whether a judgment is final must err on the side of appealing or risk losing the right to appeal.
In 1881, after struggling with these problems for many years,17 we attempted to resolve them in the case of Linn v. Arambould.18 There we stated that a final judgment after trial must dispose of the issues “intrinsically, and not inferentially.”19 That is, specificity was strictly required. The results of this rule were predictable. Appellate courts frequently declared shabbily drafted judgments interlocutory even though the trial courts and the parties had obviously intended for them to be final.20 Confused parties were spending time and money attempting to appeal from possibly final judgments, only to have the appellate courts dismiss the appeals for want of jurisdiction.21 As this Court later reflected on Arambould ⅛ intrinsic-disposition requirement for finality:
By its application most judgments easily became black or white — final or interlocutory; but all too often judgments which were obviously intended to be final were being held interlocutory because of careless draftsmanship. The rule had to be changed to accommodate oversight or carelessness.22
In 1896 we altered course. In Rackley v. Fowlkes,23 the plaintiff had, in a prior suit, sued for title to real property and for rent for the four years the property was in the defendant’s possession, but at trial he offered no evidence of the amount of rent due until after the evidence was closed, and because the offer was late the court refused to hear it. The court in that suit rendered judgment awarding title to the plaintiff without mentioning his claim for rent. When the plaintiff filed a second suit for the rent, the defendant asserted res judicata in defense. The trial court rendered judgment for the plaintiff, concluding that the rent claim had not been adjudicated in the prior suit, and the court of civil appeals affirmed. We reversed the judgments of the lower courts, not because the rent claim should have been adjudieat-[197]*197ed in the first suit, but because it was adjudicated:
The proposition seems to be sound in principle and well supported by authority that where the pleadings and judgment in evidence show that the pleadings upon which the trial was had put in issue plaintiffs right to recover upon two causes of action, and the judgment awards him a recovery upon one, but is silent as to the other, such judgment is prima facie an adjudication that he was not entitled to recover upon such other cause. This liberal construction of the judgment against the party who sought to recover therein is supported by the presumption that the court performed the duty devolved upon it upon the submission of the cause by disposing of every issue presented by the pleadings so as to render its judgment final and conclusive of the litigation, and by the further fact that the policy of the law favors the speedy settlement of litigation and opposes the harassing of the defendant with two suits for the same cause.24
Three years later we used the rule stated for purposes of res judicata in Rackley to determine whether a judgment was final for purposes of appeal. In Davies v. Thomson,25 the plaintiffs sued for money and an interest in real property as their share of a joint venture. The trial court rendered judgment on a jury verdict awarding the plaintiffs money without mentioning the claim for an interest in real property. We held that the judgment disposed of both claims was therefore final and appealable.26
Neither Rackley nor Davies mentioned Arambould or attempted to reconcile their results with the rule in that case, thereby generating confusion in the appellate courts over how to determine finality in cases involving cross-claims and counterclaims. Some courts treated judgments that merely implicitly disposed of all claims as final, while other courts required that final judgments expressly adjudicate each claim.27 In 1913, the Court resolved the conflict in Trammell v. Rosen,28 rejecting the rule stated in Arambould. The plaintiff in Trammell sued on a promissory note secured by property that the defendant and his wife claimed was their homestead. The couple counterclaimed to establish their homestead claim and for damages for wrongful sequestration. The trial court instructed a verdict for the plaintiff on his claim and against the defendants on their counterclaim. The judgment recited the verdict and awarded damages to the plaintiff but did not mention the counterclaim.29 Citing Rackley, the Court concluded that the judgment was final, reasoning that by granting the plaintiffs claim the trial court implicitly but necessarily denied the defendants’ counterclaim.30 Still, the Court strongly encouraged courts to expressly address each claim and party in final judgments to avoid further confusion:
We feel constrained to hold that the judgment of the trial court, although irregular and imperfect in form, is sufficient to support the appeal. However, we feel impelled to say, also, that we think that, as a matter of practice, and to avoid confusion, every final judgment should plainly, explicitly, and specifically dispose of each and every party to the cause, and of each and every issue therein presented by the pleadings.31
[198]*198Two eases decided after Trammell suggest that the entire record should be considered in determining whether a post-trial judgment is final. In Hargrove v. Insurance Investment Corp., we held that a judgment for the plaintiff was final when “considered as a whole in the fight of the entire record”.32 Similarly, in Ferguson v. Ferguson, we held that a judgment awarding the plaintiff recovery on some of her claims while silent as to others was final, stating that “[i]n arriving at whether or not a judgment is final, the pleadings and evidence must also be taken into consideration”.33 Neither case should be read to deviate from the presumptive rule of Trammell. We did not hold in either case that the record could be used to show that a post-trial judgment final on its face was really not final. In two other cases during the same time period we did not mention the record in applying Trammell.34,
In 1966, we reaffirmed Rackley, Davies, and Trammell in North East Independent School District v. Aldridge,35 The school district sued Aldridge for breach of contract, and he asserted in his defense that he had contracted only as an agent for his principal. He also brought a third-party action against his principal, alleging that the principal was responsible for any damages to which the school district might be entitled. The trial court granted a partial summary judgment holding Aldridge personally liable to the district and directed that the case proceed to trial to determine the amount of damages to be awarded. The parties then stipulated to the amount of damages, and the trial court rendered judgment for the district against Aldridge based on the stipulation. The judgment did not mention Aldridge’s third-party action against his principal. The court of civil appeals dismissed Aldridge’s appeal, holding that the trial court’s judgment was not final.36 We held that the judgment against Aldridge disposed of the third-party action and was final for purposes of appeal. After reviewing the courts’ historical difficulties in making finality determinations, we stated the following rule
for determining, in most instances, whether judgments in which parties and issues made by the pleadings are not disposed of in express language are, nevertheless, final for appeal purposes. When a judgment, not intrinsically interlocutory in character, is rendered and entered in a case regularly set for conventional trial on the merits, no order for a separate trial of issues having been entered ..., it will be presumed for appeal purposes that the Court intended to, and did, dispose of all parties legally before it and of all issues made by the pleadings between such parties.37
We added: “Of course, the problem [of determining whether judgments are final] can be eliminated entirely by a careful drafting of judgments to conform to the pleadings or by inclusion in judgments of a simple statement that all relief not expressly granted is denied.”38 Inclusion of a catch-all statement — which we later denominated a “Mother Hubbard” clause39— would make clear that a post-trial judgment on the merits, presumed to have disposed of all claims, did indeed do so.
[199]*199B
The presumption that a judgment rendered after a conventional trial on the merits is final and appealable has proved fairly workable for nearly a century, but we have never thought that it could be applied in other circumstances, as we first explained nearly sixty years ago. In Davis v. McCray Refrigerator Sales Corp.,40 the plaintiff sued for the unpaid balance of the purchase price of a refrigerator, and the defendant counterclaimed for cancellation of the debt and for damages for payments already made and lost merchandise due to improper refrigeration. The defendant also filed a plea in abatement on the grounds that the plaintiff was a foreign corporation not licensed to do business in Texas and therefore not entitled to sue in state court. The trial court deferred ruling on the defendant’s plea until after the case was tried on the merits. After the jury returned a verdict, the trial court rendered judgment both that the plaintiffs claim be dismissed and that the plaintiff take nothing.41 The only basis the trial court had for dismissal was the defendant’s plea in abatement, while the only basis for rendering a take-nothing judgment was plaintiffs failure of proof at trial. The judgment did not mention the defendant’s counterclaim. The court of civil appeals rejected the defendant’s argument that the judgment was interlocutory and reversed and rendered judgment for the plaintiff.42 This Court reversed and dismissed the appeal. Citing Trammell, the Court acknowledged that while a final judgment need not expressly dispose of each issue so long as other provisions of the judgment necessarily imply that the unmentioned issues have been disposed of, a dismissal of the plaintiffs suit did not necessarily imply a disposal of the defendant’s cross-action ,43 The Court explained:
[I]f the court had intended to merely sustain the plea in abatement and dismiss plaintiffs suit, and had intended to retain the defendant’s cross-action for further consideration, it would have entered the very judgment that was entered in this case. The mere failure of the judgment to refer to defendant’s cross-action was not sufficient in itself to raise an inference that it was thereby intended to dispose of the cross-action.44
Although the judgment did not “merely” sustain the plea in abatement but also decreed that the plaintiff take nothing, the inclusion of the dismissal in the judgment as the first basis for decision was enough to make Trammell’s, presumptive finality rule inapplicable.
Davis may have departed too far from Trammell. The trial court’s decree following a jury trial on the merits that the plaintiff take nothing without mention of the defendant’s counterclaim should perhaps have been presumed to deny all relief, despite the alternative ruling that the plaintiffs claim should be dismissed. But regardless of Davis’s unusual circumstances, the case makes the point, which we expressly acknowledged in Aldridge, that “[i]t will not be presumed that a judgment dismissing a plaintiffs suit on non-suit, plea to the jurisdiction, plea in abatement, for want of prosecution, etc., also disposed of the issues in an independent cross-action.”45
We have since held that “etc.” includes default judgments and summary judgments.46 The reason for not applying a presumption in any of these circumstances [200]*200is that the ordinary expectation that supports the presumption that a judgment rendered after a conventional trial on the merits will comprehend all claims simply does not exist when some form of judgment is rendered without such a trial. On the contrary, it is quite possible, perhaps even probable these days in cases involving multiple parties and claims, that any judgment rendered prior to a full-blown trial is intended to dispose of only part of the ease. Accordingly, the finality of the judgment must be determined without the benefit of any presumption.
A judgment that finally disposes of all remaining parties and claims, based on the record in the case, is final, regardless of its language.47 A judgment that actually disposes of every remaining issue in a case is not interlocutory merely because it recites that it is partial or refers to only some of the parties or claims. Thus, if a court has dismissed all of the claims in a case but one, an order determining the last claim is final.48 This is settled law in Texas, and while there have been proposals to change it by rule, proposals that are currently pending consideration by this Court’s Advisory Committee, we are not inclined to depart from it here. The language of an order or judgment cannot make it interlocutory when, in fact, on the record, it is a final disposition of the case.
But the language of an order or judgment can make it final, even though it should have been interlocutory, if that language expressly disposes of all claims and all parties. It is not enough, of course, that the order or judgment merely use the word “final”. The intent to finally dispose of the case must be unequivocally expressed in the words of the order itself. But if that intent is clear from the order, then the order is final and appealable, even though the record does not provide an adequate basis for rendition of judgment. So, for example, if a defendant moves for summary judgment on only one of four claims asserted by the plaintiff, but the trial court renders judgment that the plaintiff take nothing on all claims asserted, the judgment is final — erroneous, but final.49 A judgment that grants more relief than a party is entitled to is subject to reversal, but it is not, for that reason alone, interlocutory.50
Texas appellate courts, this Court included, have had difficulty determining when a judgment is final on its face — by its own express terms, in other words— even though it should not have been because no sufficient basis for rendering a final judgment was presented. In Schlipf v. Exxon Corp.,51 the plaintiffs sued for gas royalties and prejudgment interest, and moved for summary judgment only on the royalties issue. Neither the defendant nor an intervenor moved for summary judgment against the plaintiffs. The trial court granted the plaintiffs’ motion, awarding the royalties claimed, but denied prejudgment interest. The judgment recited:
the relief herein granted Plaintiffs, ... is in satisfaction of all of their claims and causes of action ... and all claims and/or causes of action herein asserted by all parties herein and not herein granted are hereby in all things denied and concluded.... 52
[201]*201We held that this language conclusively disposed of all parties and issues, as it clearly did, although in reaching this conclusion, we reiterated our observation in Aldridge that the finality of a judgment would be made clear “by inclusion ... of a simple statement that all relief not expressly granted is denied.”53 This observation, appropriate in Aldridge in reference to judgments after a conventional trial on the merits, was misleading in Schlipf because the only “relief’ properly under consideration when the order issued was that raised by the motion for summary judgment54 — the plaintiffs’ entitlement to royalties. After a full trial on the merits, the statement in a judgment that all relief not requested is denied signifies finality; there is no expectation that the court tried only part of the ease, absent an order for severance or separate trials. But after a motion for partial summary judgment, the same statement in a judgment is ambiguous. It may refer only to the motion on which the trial court is ruling, not to all claims of all parties, and not even to other claims of the movant.
Two years later, in Teer v. Duddlesten, we emphasized that the Aldridge language — all relief not expressly granted is denied — which we termed for the first time a “Mother Hubbard” clause, has no place in partial summary judgments because, by definition, those proceedings do not address all of the facts and issues in a case.55 A Mother Hubbard clause, we said, could not convert a partial summary judgment into a final order.56 Following Teer, most courts of appeals held that a Mother Hubbard clause could not make final a judgment rendered without a full trial,57 although other courts reached the contrary conclusion.58
We attempted to clarify matters in Mafrige v. Ross.59 There, two plaintiffs sued some twelve defendants for malicious prosecution, slander, libel, conspiracy, and negligence.60 No party other than the plaintiffs asserted any claims. The defendants, some individually and some in groups, filed a total of eight summary judgment motions, some directed against one of the plaintiffs and some against both.61 Only one motion addressed both of the plaintiffs and all of the claims asserted;62 even together, the other seven motions did not address both plaintiffs and all claims.63 The trial court granted all eight motions with eight separate orders, one for each motion.64 Each order stated that the [202]*202plaintiff or plaintiffs, depending on whether the motion had been directed at one or both, were to take nothing against the movant or movants.65 Thus, taken together, the eight orders provided that both of the plaintiffs were to take nothing against all of the defendants. On the plaintiffs’ appeal, however, the court of appeals held that there was not a final judgment because most of the defendants had not moved for summary judgment on all claims by both plaintiffs and thus were not entitled to a final judgment, and the “take nothing” language of the orders did not make them final.66 The court also held that if the orders had contained Mother Hubbard clauses they would have been final under this Court’s precedents, although the court of appeals did not agree that that would have been the proper result.67
We reversed, holding that the “take nothing” language in the eight summary judgment orders disposed of all claims asserted by both plaintiffs against each of the defendants and thus constituted a final judgment. We then explained:
If a summary judgment order appears to be final, as evidenced by the inclusion of language purporting to dispose of all claims or parties, the judgment should be treated as final for purposes of appeal. If the judgment grants more relief than requested, it should be reversed and remanded, but not dismissed. We think this rale to be practical in application and effect; litigants should be able to recognize a judgment which on its face purports to be final, and courts should be able to treat such a judgment as final for purposes of appeal.68
As examples of “language purporting to dispose of all claims or parties,” we gave not only the “take nothing” language of the orders before us, and the statement that summary judgment is granted as to all claims asserted, but also the standard Mother Hubbard clause-that all relief not expressly granted is denied.69 In so doing we revived the ambiguity created in Schlipf that Teer had tried to end.
The ambiguity has persisted in our decisions. In Martinez v. Humble Sand & Gravel, Inc.,70 we held that the inclusion of a Mother Hubbard clause in an order did not necessarily make it final. There, some but not all of the defendants moved for summary judgment, and the trial court granted the motions, dismissing the plaintiffs cause of action against “those Defendants”, but also ordering that summary judgment was proper “as to all remaining Defendants”, thereby suggesting that the court intended to render a final summary judgment.71 However, the trial court subsequently severed the summary judgment by order inviting other defendants to move on the same grounds.72 Although this order contained a Mother Hubbard clause, we held that judgment had not been rendered for the non-moving defendants.73
But in Bandera Electric Cooperative, Inc. v. Gilchrist,74 we held that a Mother Hubbard clause in a summary judgment made it final. There the plaintiff moved for summary judgment on its claims without mentioning the defendant’s counterclaims.75 The defendant did not move for summary judgment. The trial court [203]*203granted the plaintiffs motion by order that included a Mother Hubbard clause. We concluded that the order was final, albeit erroneous.76 We attempted to explain that our ruling was consistent with Martinez because the conflict in the orders involved in that ease showed that they were not final even though “a Mother Hubbard clause ... would have created a final and appealable judgment”.77 Besides its obvious inadequacy in explaining the result in Martinez, this explanation suggested that a Mother Hubbard clause would by itself make any summary judgment final, contrary to our holding in Teer.
Determining the significance of omitting a Mother Hubbard clause in an order has been no easier. In Park Place Hosp. v. Estate of Milo, we suggested that the absence of a Mother Hubbard clause indicated that a summary judgment was intended to be interlocutory.78 There, the trial court granted summary judgment for three of five remaining defendants and later severed the judgment from the case. We concluded that the judgment did not become final for purposes of appeal until it was severed, in part based on the omission of a Mother Hubbard clause. But in two other cases we held that the omission of a Mother Hubbard clause did not make a summary judgment interlocutory that otherwise appeared final. In Continental Airlines, Inc. v. Kiefer;79 the defendant moved for summary judgment “on all claims brought by” the plaintiffs. After the motion was filed, but before it was heard and decided, the plaintiffs amended their pleadings to add additional claims. The defendant did not amend its motion to addi'ess these later claims. The trial court granted what it entitled a “final summary judgment”, dismissing the plaintiffs’ cause of action — “cause”, singular — although multiple causes of action had been asserted. We held that the judgment was final, explaining as follows:
Finality “must be resolved by a determination of the intention of the court as gathered from the language of the decree and the record as a whole, aided on occasion by the conduct of the parties.” 5 Ray W. McDonald, Texas Civil PRactice § 27:4[a], at 7 (John S. Covell, ed., 1992 ed.); see Ferguson v. Ferguson, 161 Tex. 184, 338 S.W.2d 945, 947 (1960). In the circumstances described here, we think the district court intended to render a final, appealable judgment.... Neither the parties nor the court of appeals have suggested that the judgment was not final.80
The judgment did not include a Mother Hubbard clause, but we did not find its omission significant. We reached a similar conclusion in Inglish v. Union State Bank.81
In sum, our opinions have not been entirely consistent on whether the inclusion or omission of a Mother Hubbard clause does or does not indicate that a summary judgment is final for purposes of appeal. This ambivalence has resulted in considerable confusion in the courts of appeals.82
Ill
Much confusion can be dispelled by holding, as we now do, that the inclusion of a Mother Hubbard clause — by which we mean the statement, “all relief not granted is denied”, or essentially those words— [204]*204does not indicate that a judgment rendered without a conventional trial is final for purposes of appeal. We overrule Maf-rige to the extent it states otherwise. If there has been a full trial on the merits either to the bench or before a jury, the language indicates the court’s intention to finally dispose of the entire matter, assuming that a separate or bifurcated trial is not ordered. But in an order on an interlocutory motion, such as a motion for partial summary judgment, the language is ambiguous. It may mean only that the relief requested in the motion — not all the relief requested by anyone in the case— and not granted by the order is denied. The clause may also have no intended meaning at all, having been inserted for no other reason than that it appears in a form book or resides on a word processor. For whatever reason, the standard Mother Hubbard clause is used in interlocutory orders so frequently that it cannot be taken as any indication of finality.
As we have already explained, an order can be a final judgment for appeal purposes even though it does not purport to be if it actually disposes of all claims still pending in the case. Thus, an order that grants a motion for partial summary judgment is final if in fact it disposes of the only remaining issue and party in the case, even if the order does not say that it is final, indeed, even if it says it is not final. (Again, we do not consider here the various kinds of cases in which there may be more than one final judgment for purposes of appeal.) Also, an order can be final and appealable when it should not be. For example, an order granting a motion for summary judgment that addressed all of the plaintiffs claims when it was filed but did not address claims timely added by amendment after the motion was filed may state unequivocally that final judgment is rendered that the plaintiff take nothing by his suit. Granting more relief than the movant is entitled to makes the order reversible, but not interlocutory.83
While the present problems in determining whether an order is a final judgment should be lessened significantly by denying the standard Mother Hubbard clause of any indicia of finality in any order not issued after a conventional trial, the difficulty in determining what does make an order final and appealable remains. One solution would be stricter requirements for the form of a final judgment. Rule 58 of the Federal Rules of Civil Procedure takes this approach by requiring that to be final a judgment must “be set forth on a separate document” and be entered by the clerk on the civil docket. The separate-document requirement was added to the rule in 1963 to remove uncertainty over whether a trial judge’s opinion or order constituted a final judgment.84 Rule 58, with its dual requirements, “ ‘enhances certainty by insisting on formality.’ ” 85 The United States Supreme Court has insisted on strict compliance with the rale, quoting Professor Moore’s observation that the rule
“ “would be subject to criticism for its formalism were it not for the fact that something like this was needed to make certain when a judgment becomes effective, which has a most important bearing, inter alia, on the time for appeal and the making of post-judgment motions that go to the finality of the judgment [205]*205for purposes of appeal’ ”86
The one recognized exception is a party’s failure to object.87
The price of certainty, however, as federal rulemakers have come to realize, is that in many cases the failure to comply with Rule 58 means that no final judgment was ever rendered, and the time for appeal remains open.88 A proposed amendment to Rule 58 would provide that if final judgment is not rendered on a separate document, it is deemed rendered on the sixtieth day after the clerk’s entry on the civil docket.89 While this proposal helps ensure that every case will be closed, it also makes it more likely that a party will not be aware that the time for appeal is running — the problem the 1963 amendment to Rule 58 was meant to cure — because he does not know of the clerk’s entry on the civil docket.
There may be other solutions to these dilemmas which could be implemented by changes in our own rules, and this Court’s Advisory Committee is presently studying the issues. But we do not write rules by opinion.90 We must decide what Texas law requires for finality given the present rules.
In the past we have tried to ensure that the right to appeal is not lost by an overly technical application of the law.91 Fundamentally, this principle should guide in determining whether an order is final. Simplicity and certainty in appellate procedure are nowhere more important than in determining the time for perfecting appeal. From the cases we have reviewed here, we conclude that when there has not been a conventional trial on the merits, an order or judgment is not final for purposes of appeal unless it actually disposes of every pending claim and party or unless it clearly and unequivocally states that it finally disposes of all claims and all parties. An order that adjudicates only the plaintiffs claims against the defendant does not adjudicate a counterclaim, cross-claim, or third party claim, nor does an order adjudicating claims like the latter dispose of the plaintiffs claims. An order that disposes of claims by only one of multiple plaintiffs or against one of multiple defendants does not adjudicate claims by or against other parties. An order does not dispose of all claims and all parties merely because it is entitled “final”, or because the word “final” appears elsewhere in the order, or even because it awards costs. Nor does an order completely dispose of a case merely because it states that it is appealable, since even interlocutory orders may sometimes be ap-pealable. Rather, there must be some other clear indication that the trial court intended the order to completely dispose of the entire case. Language that the plaintiff take nothing by his claims in the case, or that the case is dismissed, shows finality if there are no other claims by other parties; but language that “plaintiff take nothing by his claims against X” when there is more than one defendant or other parties in the case does not indicate finality.
To determine whether an order disposes of all pending claims and parties, it may of course be necessary for the appellate court [206]*206to look to the record in the case. Thus, in the example just given, if the record reveals that there is only one plaintiff and only one defendant, X, the order is final, but if the record reveals the existence of parties or claims not mentioned in the order, the order is not final. On the other hand, an order that expressly disposes of the entire case is not interlocutory merely because the record fails to show an adequate motion or other legal basis for the disposition. The record may help illumine whether an order is made final by its own language, so that an order that all parties appear to have treated as final may be final despite some vagueness in the order itself, while an order that some party should not reasonably have regarded as final may not be final despite language that might indicate otherwise.
One may argue after Aldridge and Maf-rige that it is perilous to suggest any particular language that will make a judgment final and appealable because that language can then be inserted in orders intended to be interlocutory. But to leave in doubt the degree of clarity required for finality creates its own problems. The Mother Hubbard clause proved to give no indication of finality not just because it found its way into every kind of order, but because it was inherently ambiguous, as we have explained. A statement like, “This judgment finally disposes of all parties and all claims and is appealable”, would leave no doubt about the court’s intention. An order must be read in light of the importance of preserving a party’s right to appeal. If the appellate court is uncertain about the intent of the order, it can abate the appeal to permit clarification by the trial court.92 But if the language of the order is clear and unequivocal, it must be given effect despite any other indications that one or more parties did not intend for the judgment to be final. An express adjudication of all parties and claims in a case is not interlocutory merely because the record does not afford a legal basis for the adjudication. In those circumstances, the order must be appealed and reversed.
B
Nothing in the order in Leh-mann indicates that it is a final judgment, and it did not dispose of all pending claims and parties. The order in Hams states that plaintiffs take nothing as to “one of the defendants”, but that language does not suggest that all of the plaintiffs’ claims were denied. As the order recites and as the record demonstrates, the defendant named in the order was not the only defendant remaining in the case. Thus, we conclude that a final and appealable judgment was not rendered in either case.
We are concerned that in neither case were the non-movants provided a copy of the court’s signed order but were merely sent notice by postcard that an order had been signed. The Rules of Civil Procedure do not require clerks to send all parties copies of all orders, only final orders.93 Nevertheless, the practice of courts in some counties is to require that a party seeking an order provide copies and addressed, postage-paid envelopes for all other parties. The Court’s Advisory Committee should consider whether the rules should require that all parties be given copies of all orders signed in a case.
IV
We must respond briefly to the concurring opinion. It would hold that no “type of conclusory finality language can ever be read to grant more relief than requested by the parties.”94 This goes too far. The legitimate problem with Mother Hubbard clauses, which we failed to appreciate in Mafrige, is that they are ambiguous: one cannot be sure whether the denial of all relief other than what has been expressly [207]*207granted is limited to relief requested in a motion or extends to all relief requested in the litigation. But it is a long way from the now well-established fact that Mother Hubbard clauses can understandably be misread to the concurring opinion’s conclusion that clear language should be given no meaning. We require certainty for finality, but we cannot say that certainty is impossible.
The concurring opinion claims as authority for its position pre-Majrige law, but before Mafrige, this Court repeatedly held that general language in a summary judgment finally disposed of the litigation even though no party had requested final relief. In Schlipf v. Exxon Corp. we held that an order granting the plaintiffs’ motion for summary judgment on one of its claims and generally denying all other relief was final, even though no defendant had moved for summary judgment or requested the denial of any relief.95 Similarly, in Chessher v. Southwestern Bell Telephone Co. we held that a summary judgment generally disposing of all four claims asserted by the plaintiff was final, even though the defendant moved for summary judgment on only one of the claims.96 Again in Young v. Hodde, we agreed that a Mother Hubbard clause in an order granting summary judgment for the plaintiff disposed of a defendant’s counterclaim, even though the plaintiffs motion had addressed only his own claims and not the counterclaim.97 It has simply never been the law in Texas that a summary judgment generally disposing of all claims and parties is nevertheless interlocutory merely because rendition of a final judgment was improper. In essence, the concurring opinion’s position is that a trial court has no jurisdiction to grant more relief than is requested, and that if it does so, its action is absolutely void. We do not agree that a court’s power to act, as distinct from the proper exercise of that power, is defined by a party’s request for relief.
The concurring opinion acknowledges that its position may result in more appeals being taken from orders that look final but are really interlocutory, but it argues that appellate courts can easily deal with such problems by abating appeals to allow trial courts to clarify their orders. What the concurring opinion ignores is that trial courts and parties will assume that orders with general dispositive language mean what they say, only to learn months or years after an appeal should have been taken that no final judgment was ever rendered. Justice Baiíer would insist that every order granting summary judgment
specifically identify: (1) the claims each party brought; (2) the grounds upon which each party seeks summary judgment; (3) each ground upon which the trial court granted summary judgment; and (4) each ground upon which the trial court denied summary judgment.
Any order that failed to meet these requirements would be interlocutory, according to Justice Baker, “regardless of how clearly it states that it is a final judgment disposing of all parties and issues.”98 The very real risk of such a rule is that thousands of judgments intended to be final would remain interlocutory because they did not comply with all of these require[208]*208ments. This is precisely what has happened in the federal system, as we have already explained, even though the federal rules impose far fewer requirements on final judgments than the concurring opinion would.
[[Image here]]
For the reasons we have explained, the judgments of the court of appeals in these eases are reversed, and the cases are remanded to that court for further proceedings.