Hill v. Hill – Case Brief Summary (Texas)

In Hill v. Hill, 971 S.W.2d 153 (Tex.App.-Amarillo 1998, no pet.), the trial court filed no separate findings of fact and conclusions of law, rather the necessary findings and conclusions were in the judgment. Id. at 157.

In Hill the Court recognized that filing the findings in the judgment was contrary to Rule 299a of the Texas Rules of Civil Procedure, however, we stated that findings in the judgment were not shorn of all authority. Id.

Those findings in the judgment have probative value as long as they do not conflict with findings filed in a separate document. Id.

Thus, the Court reasoned that findings in the judgment could be considered because they revealed the basis for the trial court's decision. Id.

On this basis, the Court affirmed that portion of the trial court's judgment which included the findings.