Does a statement of decision need to discuss each point listed in the request?

California, United States of America


The following excerpt is from Cordray v. Lee, H036826 (Cal. App. 2012):

A statement of decision need not discuss each point listed in a request for statement of decision. It need only set forth ultimate facts as opposed to evidentiary facts on the principal controverted issues requested. Thus, if the appealed judgment is otherwise supported by the findings made, the trial court's failure to make findings on other issues is not reversible error. (In re Marriage of Garrity & Bishton (1986) 181 Cal.App.3d 675, 687; In re Marriage of Burkle (2006) 139 Cal.App.4th 712, 736, fn. 15 [statement of decision sufficient if it fairly discloses judge's determination of ultimate facts and material issues; trial court not required to respond point by point to issues posed]; Central Valley General Hospital v. Smith (2008) 162 Cal.App.4th 501, 513.)

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