Bevli v. Brisco

In Bevli v. Brisco (1985) 165 Cal. App. 3d 812, in a proceeding for administrative mandate, the trial court denied a request for a statement of decision on the ground the request was untimely, because the request was made after submission of the case and the trial had lasted less than one day. The trial judge disclosed that he had spent some 13 hours reading the administrative record. The Court of Appeal reversed, concluding that the time spent perusing the administrative record had to be considered for purposes of determining whether the trial had lasted more than one day. The court said, "If . . . time is expended by the trial court in absorbing the evidentiary information for trial, it must be considered as trial time for the purposes of findings under . . . section 632." (Id. at p. 822.)