California, United States of America
The following excerpt is from Young v. Cal. Fish & Game Comm'n, 235 Cal.Rptr.3d 366, 24 Cal.App.5th 1178 (Cal. App. 2018):
Young complains that the trial court did not issue a statement of decision and that reversal is required. Code of Civil Procedure section 632 provides in part: "In superior courts, upon the trial of a question of fact by the court, written findings of fact and conclusions of law shall not be required. The court shall issue a statement of decision explaining the factual and legal basis for its decision as to each of the principal controverted issues at trial upon the request of any party appearing at the trial." Young requested a statement of decision. Here, the trial court specifically stated it was only deciding issues of law and that there was no dispute as to the facts. "It is axiomatic that a statement of decision is required only as to issues of fact decided by the trial court ( [Code Civ. Proc.,] 632 : upon the trial of a question of fact by the court), not as to issues of law." ( City of Coachella v. Riverside County Airport Land Use Com. (1989) 210 Cal.App.3d 1277, 1291-1292, 258 Cal.Rptr. 795.) No statement of decision was required.
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