Werden v. Crawford

The sole issue presented for our determination is whether Civ. R. 52 requires a trial court to issue findings of fact and conclusions of law after it is requested to do so by a party to a proceeding on a motion for change of custody.

Civ. R. 52 states in pertinent part:

“When questions of fact are tried by the court without a jury, judgment may be general for the prevailing party unless one of the parties in writing or orally in open court requests otherwise * * * in which case, the court shall state in writing the conclusions of fact found separately from the conclusions of law.”

The trial…