DGHI Enterprises v. Pacific Cities, Inc.

— A successor judge cannot ordinarily enter findings of fact or conclusions of law based on evidence heard by a predecessor. In this case, however, the trial judge clearly and on the record adopted the findings and conclusions at issue. The act of the successor judge in entering them was therefore ministerial.

Judge McCutcheon conducted the trial in this case. He granted dismissal of certain claims and expressed his intention to adopt certain proposed findings and conclusions. He ordered a prevailing party to conform those proposed findings and conclusions to the oral ruling. Written…