Issue: Under Illinois law, in a bench trial, how detailed must the trial court’s findings of fact be?
|Area of Law:||Litigation Practice & Procedure, Litigation Practice and Procedure|
|Keywords:||; Finding of Fact; Bench Trial|
During a bench trial, the trial court is not required to mention everything-or anything-that contributed to its findings. People v. Curtis, 296 Ill. App. 3d 991, 1000 (1998). "In a bench trial, even though it may be desirable for the trial court to explain its decision, the court’s election not to comment or its failure to specifically mention certain portions of the testimony does not permit a defendant on appeal to claim that those portions not mentioned played no role in the court’s determination." Id. Accordingly, "[i]f the record contains facts which support an affirmance of the trial court’s finding, the reviewing court may take those facts into account even if the trial court did not state it explicitly relied upon them." Id. Regardless of the court’s focus on co-respondent, the record supports affirmance of the trial court’s ruling.
In re Bruce G., No. 1-15-1996 2016.IL.000026 (Ill. App. Dist.1 02/04/2016).
Date: March 1, 2016