Skelton v. Roberts

I respectfully dissent for the reasons that follow.

My colleagues, although agreeing that the requirements of CR 52.01 permit rendering oral findings of fact and conclusions of law by dictating them into the record, concluded that in this instance the trial court did not comply with the provisions of CR 52.01. I disagree.

Here the trial court made a dictated record oral decision that embodied findings of facts and conclusions of law. While they were not labeled or compartmentalized as such, their rendition was, nonetheless, functionally accomplished. The fact that they are contained in their…