implied findings doctrine in California

2026“Under the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 48 .) Here, the parties did not secure a statement of decision.

2026(Sutter Health Uninsured Pricing Cases (2009) 171 Cal.App.4th 495, 498 .) Further, under the doctrine of implied findings, we are required “to infer the trial court made all factual findings necessary to support the judgment. [Citation.]” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 58 .) We therefore must conclude that, either implicitly or explicitly, the trial court found good cause had been shown for the court to exercise its considerable discretion to extend the time to file the motion.8 E.

2025(In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133-1134 [“The clear implication of [C.C.P. §634] . . . is that if a party does not bring . . . deficiencies to the trial court’s attention, that party waives the right to claim on appeal that the statement was deficient . . . , and . . . the appellate court will imply findings to support the judgment,”]; see Abdelquader v. Abraham (2022) 76 Cal.App.5th 186 , 197 [doctrine of implied findings applies “when parties waive a statement of decision expressly or by not requesting one in a timely manner”].) And a party may usually avoid the doctrin

2025DISCUSSION A. Standard of Review “A judgment or order of a lower court is presumed to be correct on appeal, and all intendments and presumptions are indulged in favor of its correctness.” (In re Marriage of Arceneaux 9 (1990) 51 Cal.3d 1130, 1133 ; accord, Kaushansky v. Stonecroft Attorneys, APC (2025) 109 Cal.App.5th 788 , 799.) The appellant carries “the burden to prove otherwise by presenting legal authority on each point made and factual analysis, supported by appropriate citations to the material facts in the record.” (Keyes v. Bowen (2010) 189 Cal.App.4th 647, 655-656 .) “ ‘[U]nder the d

2023Under the doctrine of implied findings, “in the absence of a statement of decision, an appellate court will presume that the trial court made all factual findings necessary to support the judgment for which substantial evidence exists in the record.” (Shaw v. County of Santa Cruz (2008) 170 Cal.App.4th 229, 267 , fn. omitted.) This is true even where, as here, the trial court has offered a rationale orally.

2022Second, the appellate court applies the doctrine of implied findings and presumes the trial court made all necessary findings supported by substantial evidence.’ ” (Carbajal v. CWPSC, Inc. (2016) 245 Cal.App.4th 227, 237 , quoting Acquire II, Ltd. v. Colton Real Estate Group (2013) 213 Cal.App.4th 959, 970 .) Stated another way, under the doctrine of implied findings, “the necessary findings of ultimate facts will be implied and the only issue on appeal is whether the implied findings are supported by substantial evidence.” (Shaw v. County of Santa Cruz (2008) 170 Cal.App.4th 229, 267 (Shaw).)

2025Indeed, because Chimienti did not object to the statement of decision regarding what facts were known to him, the doctrine of implied findings applies. “‘A judgment or order of a lower court is presumed to be correct on appeal, and all intendments and presumptions are indulged in favor of its correctness.’ [Citation.] Specifically, ‘[u]nder the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.’ [Citation.]” (Thompson, supra, 6 Cal.App.5th at p. 981 .) This includes

2025(Rule 3.1590(h)-(l).) “ ‘A judgment or order of a lower court is presumed to be correct on appeal, and all intendments and presumptions are indulged in favor of its correctness.’ ” (Kaushansky v. Stonecroft Attorneys, APC (2025) 109 Cal.App.5th 788 , 799.) Generally, “[u]nder the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 48 .) But if a party requests a statement of decision and “the statemen

2024(Fladeboe, supra, 150 Cal.App.4th at p. 58 ; see Acquire II, Ltd. v. Colton Real Estate Group (2013) 213 Cal.App.4th 959, 970 [under doctrine of implied findings, appellate court presumes trial court made all necessary findings supported by substantial evidence].) An example of the doctrine being applied to a claim for attorney fees under section 800 is provided by Halaco, supra, 42 10.

2023Under the doctrine of implied findings, an appellate court “presumes the trial court made all necessary findings supported by substantial evidence.” (Acquire II, Ltd. v. Colton Real Estate Group (2013) 213 Cal.App.4th 959, 970 .) Thus, a finding can be inferred only if it is supported by substantial evidence.

2025Second, even if the doctrine of implied findings applied, the doctrine is intended to address situations in which “factual findings are not expressly made,” and the appellate court must “fill in the gap by presuming the missing finding was decided in favor of the prevailing party.” (People v. Ashford University, LLC (2024) 100 Cal.App.5th 485 , 525; Ermoian, supra, 152 Cal.App.4th at p. 494 [The doctrine of implied findings applies “when the court’s statement of decision is ambiguous or omits material factual findings.”].) It is not intended to substitute different factual findings where the t

2025Second, even if the doctrine of implied findings applied, the doctrine is intended to address situations in which “factual findings are not expressly made,” and the appellate court must “fill in the gap by presuming the missing finding was decided in favor of the prevailing party.” (People v. Ashford University, LLC (2024) 100 Cal.App.5th 485 , 525; Ermoian, supra, 152 Cal.App.4th at p. 494 [The doctrine of implied findings applies “when the court’s statement of decision is ambiguous or omits material factual findings.”].) It is not intended to substitute different factual findings where the t

2024“Under the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.” (Fladeboe v. American Isuzu Motors, Inc. (2007) 150 Cal.App.4th 21 42, 48 (Fladeboe).) “The doctrine of implied findings requires the appellate court to infer the trial court made all factual findings necessary to support the judgment.” (Id., citing Sammis v. Stafford (1996) 48 Cal.App.4th 1935, 1942 .) “The doctrine is a natural and logical corollary to three fundamental principles of appellate review: (

2023“A judgment or order of a lower court is presumed to be correct on appeal, and all intendments and presumptions are indulged in favor of its correctness.” (In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133 ; accord Jameson v. Desta (2018) 5 Cal.5th 594 , 608–609 (Jameson); Denham v. Superior Court (1970) 2 Cal.3d 557, 564 (Denham) [“ ‘All intendments and presumptions are indulged to support it on matters as to which the record is silent, and error must be affirmatively shown.’ ”].) “[T]he burden is on appellant to demonstrate, on the basis of the record presented to the appellate court,

2024“Under the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.” (Fladeboe v. American Isuzu Motors, Inc. (2007) 150 Cal.App.4th 21 42, 48 (Fladeboe).) “The doctrine of implied findings requires the appellate court to infer the trial court made all factual findings necessary to support the judgment.” (Id., citing Sammis v. Stafford (1996) 48 Cal.App.4th 1935, 1942 .) “The doctrine is a natural and logical corollary to three fundamental principles of appellate review: (

2020“A judgment or order of a lower court is presumed to be correct on appeal, and all intendments and presumptions are indulged in favor of its correctness.” (In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133 (Arceneaux).) In a court trial, application of this fundamental principle triggers the doctrine of implied findings: Because “the reviewing court presumes that the trial court made all factual findings necessary to support the judgment” for which there is substantial evidence (In re Marriage of Fong (2011) 193 Cal.App.4th 278, 293 ; see In re Marriage of Sahafzadeh-Taeb & Taeb (2019) 3

2021(Compare In re Marriage of Fingert (1990) 221 Cal.App.3d 1575, 1580 [finding doctrine inapplicable] and In re Marriage of Seaman & Menjou (1991) 1 Cal.App.4th 1489, 1494, fn. 3 [same] with In re Marriage of McHugh (2014) 231 Cal.App.4th 1238 , 1248- 1249 [applying doctrine]; see discussion in A.G. v. C.S. (2016) 246 Cal.App.4th 1269, 1281-1282 .) We agree with the McHugh court’s assessment that Fingert “cited no authority establishing an exception to the implied findings doctrine for an appeal based on a settled statement” and that Seaman & Menjou followed Fingert without analysis.

2016(See In re Marriage of Condon, supra, 62 Cal.App.4th at p. 550, fn. 11 ; In re Marriage of Seaman & Menjou (1991) 1 Cal.App.4th 1489, 1494, fn. 3 [ 2 Cal.Rptr.2d 690 ]; In re Marriage of Fingert (1990) 221 Cal.App.3d 1575, 1580 [ 271 Cal.Rptr. 389 ].) Another appellate district has joined with legal commentators to refuse to acknowledge an exception to the implied findings doctrine when the parties do not request a statement of decision.

2016Generally, “[u]nder the doctrine of ‘implied findings,’ when parties waive a statement of decision expressly or by not requesting one in a timely manner, appellate courts reviewing the appealed judgment must presume the trial court made all factual findings necessary to support the judgment for which there is substantial evidence. [Citations.]” (In re Marriage of Condon (1998) 62 Cal.App.4th 533, 550, fn. 11 [ 73 Cal.Rptr.2d 33 ].) Some appellate districts have held the doctrine of implied findings does not apply where a statement of decision is waived, a settled statement is used in place of

2016Generally, “[u]nder the doctrine of ‘implied findings,’ when parties waive a statement of decision expressly or by not requesting one in a timely manner, appellate courts reviewing the appealed judgment must presume the trial court made all factual findings necessary to support the judgment for which there is substantial evidence. [Citations.]” (In re Marriage of Condon (1998) 62 Cal.App.4th 533, 550, fn. 11 [ 73 Cal.Rptr.2d 33 ].) Some appellate districts have held the doctrine of implied findings does not apply where a statement of decision is waived, a settled statement is used in place of

2025Group (1964) 230 Cal.App.2d 788, 796 [reviewing if insurance company acted in good faith in refusing to settle].) “‘Because the good faith issue is factual, the question on appeal will be whether the evidence of record was sufficient to sustain the trial court’s finding.’ [Citation.]” (Clark v. Optical Coating Laboratory, Inc., supra, 165 Cal.App.4th at p. 183 .) The trial court, in denying defendant’s in limine motion, did not state why it did so, and under “the doctrine of implied findings . . . the appellate court is required to infer that the trial court made all factual findings necessary

2023(Rudnick, supra, 179 Cal.App.4th at p. 1335 ; see also Laabs, supra, 163 3 In his opposition to respondent’s motion for appellate sanctions, appellant contends that the standard of review is better described as the “presumption of correctness” than as the “ ‘doctrine of implied findings,’ ” a term sometimes reserved for circumstances in which the parties may request a statement of decision under Code of Civil Procedure section 632, which applies to trials rather than motions.

2026(Id. at p. 1462; see Payton v. CSI Electrical Contractors, Inc. (2018) 27 Cal.App.5th 832, 843 [“The existence of any common policy is not sufficient .… The policy in question must be a means to establish liability on a classwide basis”].) The Doctrine of Implied Findings is Not Applicable “[I]t is a fundamental principle of appellate procedure that a trial court judgment is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgme

2025(Jameson v. Desta (2018) 5 Cal.5th 594 , 608–609; accord, Universal Home Improvement, Inc. v. Robertson (2020) 51 Cal.App.5th 116 , 125.) The doctrine of implied findings is “natural and logical corollary” to these fundamental principles.

2026Co. (2004) 121 Cal.App.4th 452, 462 [explaining that the doctrine of implied findings “(1) directs the appellate court to presume that the trial court made all factual findings necessary to support the judgment so long as substantial evidence supports those findings and (2) applies unless the omissions and 5 A. Standard of Review “We apply a de novo standard of review to the legal question of whether the doctrine of exhaustion of administrative remedies applies in a given case.” (Citizens for Open Government v. City of Lodi (2006) 144 Cal.App.4th 865, 873 .) B.

2014Co. (2004) 121 Cal.App.4th 452, 462 [explaining that the doctrine of implied findings “(1) directs the appellate court to presume that the trial court made all factual findings necessary to support the judgment so long as substantial evidence supports those findings and (2) applies unless the omissions and ambiguities in the statement of decision are brought to the attention of the superior court in a timely manner”].) The school relies on the futility doctrine to excuse the requirement of administrative exhaustion.

2021(Compare In re Marriage of Fingert (1990) 221 Cal.App.3d 1575, 1580 [finding doctrine inapplicable] and In re Marriage of Seaman & Menjou (1991) 1 Cal.App.4th 1489, 1494, fn. 3 [same] with In re Marriage of McHugh (2014) 231 Cal.App.4th 1238 , 1248- 1249 [applying doctrine]; see discussion in A.G. v. C.S. (2016) 246 Cal.App.4th 1269, 1281-1282 .) We agree with the McHugh court’s assessment that Fingert “cited no authority establishing an exception to the implied findings doctrine for an appeal based on a settled statement” and that Seaman & Menjou followed Fingert without analysis.

2016(See In re Marriage of Condon, supra, 62 Cal.App.4th at p. 550, fn. 11 ; In re Marriage of Seaman & Menjou (1991) 1 Cal.App.4th 1489, 1494, fn. 3 [ 2 Cal.Rptr.2d 690 ]; In re Marriage of Fingert (1990) 221 Cal.App.3d 1575, 1580 [ 271 Cal.Rptr. 389 ].) Another appellate district has joined with legal commentators to refuse to acknowledge an exception to the implied findings doctrine when the parties do not request a statement of decision.

2022Corp. (2021) 60 Cal.App.5th 572 , 581.) “ ‘ “In other words, the necessary findings of ultimate facts will be implied and the only issue on appeal is whether the implied findings are supported by substantial evidence.” ’ [Citation.] The doctrine of implied findings ‘is a natural and logical corollary to three fundamental principles of appellate review: (1) a judgment is presumed correct; (2) all intendments and presumptions are indulged in favor of correctness; and (3) the appellant bears the burden of providing an adequate record affirmatively proving error.’ ” (Abdelqader v. Abraham (2022) 7

2022Corp. (2021) 60 Cal.App.5th 572 , 581.) “ ‘ “In other words, the necessary findings of ultimate facts will be implied and the only issue on appeal is whether the implied findings are supported by substantial evidence.” ’ [Citation.] The doctrine of implied findings ‘is a natural and logical corollary to three fundamental principles of appellate review: (1) a judgment is presumed correct; (2) all intendments and presumptions are indulged in favor of correctness; and (3) the appellant bears the burden of providing an adequate record affirmatively proving error.’ ” (Abdelqader v. Abraham (2022) 7

2022First, the appellant must request a statement of decision pursuant to [Code of Civil Procedure] section 632; second, if the trial court issues a statement of decision, “a party claiming omissions or ambiguities in the factual findings must bring the omissions or ambiguities to the trial court’s attention” pursuant to [Code of Civil Procedure] section 634.’ [Citations.]” (Orange County Water Dist. v. Alcoa Global Fasteners, Inc. (2017) 12 Cal.App.5th 252, 311-312 (Orange County Water Dist.).) Code of Civil Procedure section 634 requires an omission or ambiguity to be “brought to the attention o

2022(See Orange County Water Dist. v. Alcoa Global Fasteners, Inc. (2017) 12 Cal.App.5th 252, 312 [“the doctrine of implied findings does not apply to the court’s legal conclusions (which are reviewed de novo on appeal)”].) We reject these reply brief contentions, for two reasons.

2024(Gajanan Inc. v. City and County of San Francisco (2022) 77 Cal.App.5th 780 , 791–792.) “We apply a 22 substantial evidence standard of review to the trial court’s findings of fact.” (Thompson v. Asimos (2016) 6 Cal.App.5th 970, 981 (Thompson).) “Under this deferential standard of review, findings of fact are liberally construed to support the judgment and we consider the evidence in the light most favorable to the prevailing party, drawing all reasonable inferences in support of the findings.” (Ibid.) Under the doctrine of implied findings, “ ‘the reviewing court must infer, following a bench

2024(Gajanan Inc. v. City and County of San Francisco (2022) 77 Cal.App.5th 780 , 791–792.) “We apply a 22 substantial evidence standard of review to the trial court’s findings of fact.” (Thompson v. Asimos (2016) 6 Cal.App.5th 970, 981 (Thompson).) “Under this deferential standard of review, findings of fact are liberally construed to support the judgment and we consider the evidence in the light most favorable to the prevailing party, drawing all reasonable inferences in support of the findings.” (Ibid.) Under the doctrine of implied findings, “ ‘the reviewing court must infer, following a bench

2025When the parties fail to timely request a statement of decision, we apply the doctrine of implied findings under which we “‘must presume the trial court made all factual findings necessary to support the judgment for which there is substantial evidence.’” (In re Marriage of McHugh (2014) 231 Cal.App.4th 1238, 1248 .) “A party who does not request a statement of decision may not argue the trial court failed to make any finding required to support its decision.” (Ibid.) Accordingly, the lack of a statement of decision precludes any argument that the trial court did not properly consider all the

2024Further, having thus waived, they argue that under the doctrine of implied findings, we “ ‘must presume the trial court made all factual findings necessary to support the judgment for which there is substantial evidence.’ ” (In re Marriage of McHugh (2014) 231 Cal.App.4th 1238, 1248 (McHugh).) Father disputes this conclusion, arguing he was not entitled to request a statement of decision on a motion and, therefore, the doctrine of implied findings does not apply.

2026(Brewer v. Carter (2013) 218 Cal.App.4th 1312, 1320 .) Accordingly, we presume the court found that the post-bid changes were not material, did not mislead bidders, did not confer an unfair advantage, and did not violate competitive bidding requirements or the City Charter.

2020If analysis of the record suggests the contrary, the rule should not be invoked.’ ” (Brewer v. Carter, supra, 218 Cal.App.4th at p. 1320 .) Mother argues the implied findings doctrine cannot “be relied upon to affirm the court’s jurisdictional order in the complete absence of any evidence the trial court carried out its mandatory statutory duty.” She appears to argue that, when the record is silent as to whether the trial judge weighed the evidence, as here, no presumption of correctness applies.

2025When no statement of decision is issued, or when a statement of decision is issued but the parties fail to object “to any ambiguities or omissions in it, the doctrine of implied findings applies. ‘The doctrine of implied findings requires the appellate court to infer the trial court made all factual findings necessary to support the judgment. [Citation.] The doctrine is a natural and logical corollary to three fundamental principles of appellate review: (1) a judgment is presumed correct; (2) all intendments and presumptions are indulged in favor of correctness; and (3) the appellant bears the

2020(County of Orange v. Barratt American, Inc. (2007) 150 Cal.App.4th 420, 437-438 .) This is the doctrine of implied findings, and it “‘is a natural and logical corollary to three fundamental principles of appellate review: (1) a judgment is presumed correct; (2) all intendments and presumptions are indulged in favor of correctness; and (3) the appellant bears the burden of providing an adequate record affirmatively proving error.’” (Id. at p. 439.)4 This is a wage-and-hour misclassification case relating to the application of an exemption to Ruan’s obligation to pay overtime and provide meal br

2023(See Wegner et al., Cal. Practice Guide: Civil Trials and Evidence (The Rutter Group 2022) ¶¶ 16:197 to 16:205.) “Under the doctrine of implied findings, the reviewing court must infer, following a bench trial, that the trial court impliedly made every factual finding necessary to support its decision.” (Fladeboe v. American Isuzu Motors, Inc. (2007) 150 Cal.App.4th 42, 48 .) Under section 632, upon a party’s request after trial, the court must issue a statement of decision “explaining the factual and legal basis for its decision as to each of the principal controverted issues at trial.” Under

2023(See Arceneaux, supra, 51 Cal.3d at p. 1137 ; Culbertson, supra, 225 Cal.App.2d at pp. 465-466.) We conclude the SOD is similarly flawed regarding the trial court’s finding that Lennar paid Casa Verde $17,184 under change order No. 2.

2025(Espinoza v. Shiomoto (2017) 10 Cal.App.5th 85, 100 [“The doctrine of implied findings ‘requires . . . an appellate court [to] presume that the trial court made all factual findings necessary to support the judgment for which substantial evidence exists in the record.

2022We disagree. “ ‘Under the doctrine of “implied findings,” when parties waive a statement of decision expressly or by not requesting one in a timely manner, appellate courts reviewing the appealed judgment must presume the trial court made all factual findings necessary to support the [order] for which there is substantial evidence.’ ” (In re Marriage of McHugh (2014) 231 Cal.App.4th 1238, 1248 .) “In other words, the necessary findings of ultimate facts will be implied and the only issue on appeal is whether the implied findings are supported by substantial evidence.” (Espinoza v. Shiomoto (20

2024(Gajanan Inc. v. City and County of San Francisco (2022) 77 Cal.App.5th 780 , 791–792.) “We apply a 22 substantial evidence standard of review to the trial court’s findings of fact.” (Thompson v. Asimos (2016) 6 Cal.App.5th 970, 981 (Thompson).) “Under this deferential standard of review, findings of fact are liberally construed to support the judgment and we consider the evidence in the light most favorable to the prevailing party, drawing all reasonable inferences in support of the findings.” (Ibid.) Under the doctrine of implied findings, “ ‘the reviewing court must infer, following a bench

2024(Gajanan Inc. v. City and County of San Francisco (2022) 77 Cal.App.5th 780 , 791–792.) “We apply a 22 substantial evidence standard of review to the trial court’s findings of fact.” (Thompson v. Asimos (2016) 6 Cal.App.5th 970, 981 (Thompson).) “Under this deferential standard of review, findings of fact are liberally construed to support the judgment and we consider the evidence in the light most favorable to the prevailing party, drawing all reasonable inferences in support of the findings.” (Ibid.) Under the doctrine of implied findings, “ ‘the reviewing court must infer, following a bench

2025(A.G. v. C.S. (2016) 246 Cal.App.4th 1269, 1281-1282 .) “The doctrine of implied findings requires the appellate court to infer the trial court made all factual findings necessary to support the judgment [or order].” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 58 .) Renewal of DVRO Family Code section 6345, subdivision (a) provides that a DVRO “may be renewed, upon the request of a party, either for five or more years, or permanently, at the discretion of the court, without a showing of further abuse since the issuance of the original order.” “The legal standard for rene

2021(Compare In re Marriage of Fingert (1990) 221 Cal.App.3d 1575, 1580 [finding doctrine inapplicable] and In re Marriage of Seaman & Menjou (1991) 1 Cal.App.4th 1489, 1494, fn. 3 [same] with In re Marriage of McHugh (2014) 231 Cal.App.4th 1238 , 1248- 1249 [applying doctrine]; see discussion in A.G. v. C.S. (2016) 246 Cal.App.4th 1269, 1281-1282 .) We agree with the McHugh court’s assessment that Fingert “cited no authority establishing an exception to the implied findings doctrine for an appeal based on a settled statement” and that Seaman & Menjou followed Fingert without analysis.