Hughes v. Hughes

A case involving a motion for a change of custody contemplates an order which necessarily must be based upon the determination of factual issues and the application of governing statutes; and this proceeding was subject,therefore, to the provisions of Civ. R. 52, which provides, among other things, that if a timely request is made for findings of fact stated separately from conclusions of law, then “the court shall state in writing the conclusions of fact found separately from the conclusions of law.”

The duty imposed by Civ. R. 52 was extracted directly from former R. C. 2315.22. In Bauer v.…