Whittington v. McKinney

In Whittington v. McKinney (1991) 234 Cal. App. 3d 123, the court found that failure to prepare a written statement of decision was reversible error, but that a party could waive the right to a written statement. The court concluded that, because the trial court had repeatedly asked both parties whether an oral statement of decision was acceptable and appellant neither objected to the procedure nor insisted on her right to a written statement, she waived this right. ( Id. at p. 130.)