In Re Marriage of Arceneaux

Opinion

MOSK, J.

Does a litigant who fails to bring to the attention of the trial court alleged deficiencies in the court’s statement of decision waive the right to complain of such errors on appeal, thereby allowing the appellate court to make implied findings in favor of the prevailing party? We conclude that a waiver occurs in these circumstances pursuant to section 634 of the Code of Civil Procedure, and therefore affirm the judgment of the Court of Appeal.

In a dissolution action, the trial court orally announced its intended decision on January 28, 1986. Husband filed a request for a…