Legal Memorandum: Reversal of a Trial Court's Decision

Issue: Under Minnesota law, will a trial court’s decision be reversed for failure to make findings of fact or conclusions of law?

Area of Law: Litigation & Procedure
Keywords: Trial court's decision; Reversal; Findings of fact or conclusions of law
Jurisdiction: Minnesota
Cited Cases: 135 N.W.2d 199; 336 N.W.2d 307; 206 N.W.2d 347
Cited Statutes: Minn. R. Civ. P. 52.01; Minn. R. Civ. P. 52.02; Minn. R. Civ. P. 59.03, R. 59.01,
Date: 11/01/2004

A trial court’s decision is not subject to attack for failure to issue findings of fact and conclusions of law.  Findings of fact and conclusions of law are not required in decisions on motions.  Minn. R. Civ. P. 52.01. 

However, a post-trial motion to amend the findings of fact (or to make them in the first instance) would be an appropriate plan and preferable to a direct appeal from the trial court’s order.  A party could bring a post-trial motion to make findings of fact under Minn. R. Civ. P. 52.02, which provides:

Upon motion of a party served and heard not later than the times allowed for a motion for new trial pursuant to Rule 59.03 [30 days], the court may amend its findings or make additional findings, and may amend the judgment accordingly if judgment has been entered.  The motion may be made with a motion for a new trial and may be made on the files, exhibits, and minutes of the court.  When findings of fact are made in actions tried by the court without a jury, the question of the sufficiency of the evidence to support the findings may thereafter be raised whether or not the party raising the question has made in the district court an objection to such findings or has made a motion to amend them or a motion for judgment.

Minn. R. Civ. P. 52.02.  See also id., R. 59.03 (motion for new trial); R. 59.01 […]

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