What Is a Statement of Decision In California ?
Upon the timely request of one of the parties in a nonjury trial, a trial court is required to render a statement of decision addressing the factual and legal bases for its decision as to each of the principal controverted issues of the case. (Code Civ. Proc., 632.)
A statement of decision need not address all the legal and factual issues raised by the parties. Instead, it need do no more than state the grounds upon which the judgment rests, without necessarily specifying the particular evidence considered by the trial court in reaching its decision. (Haight v. Handweiler (1988) 199 Cal. App. 3d 85, 89-90 244 Cal. Rptr. 488; Aviointeriors SpA v. World Airways, Inc. (1986) 181 Cal. App. 3d 908, 913-914 226 Cal. Rptr. 527.)
"A trial court rendering a statement of decision under . . . section 632 is required to state only ultimate rather than evidentiary facts because findings of ultimate facts necessarily include findings on all intermediate evidentiary facts necessary to sustain them. Citation." (In re Cheryl E. (1984) 161 Cal. App. 3d 587, 599 207 Cal. Rptr. 728; accord, People v. Casa Blanca Convalescent Homes, Inc. (1984) 159 Cal. App. 3d 509, 524 206 Cal. Rptr. 164, 53 A.L.R.4th 661, disapproved on other grounds in Cal-Tech Communications, Inc. v. Los Angeles Cellular Telephone Co. (1999) 20 Cal. 4th 163, 184-185 83 Cal. Rptr. 2d 548, 973 P.2d 527.)
In other words, a trial court rendering a statement of decision is required only to set out ultimate findings rather than evidentiary ones.