Also known as:legal conclusions · conclusion of law · conclusions of law
Written by attorneys · grounded in primary & secondary sources — see below
A statement that expresses a legal duty or result but omits the facts creating or supporting the duty or result. Such statements receive no deference on review and must be distinguished from findings of fact that rest on evidence.
Sources & Authorities
How it applies
Common Examples
6
Bench Trial Findings Required
Lily Lopez sued Legacy Motors after a bench trial on contract performance. The district court announced only that Legacy Motors had breached and entered judgment. On appeal the circuit court held the announcement was a bare legal conclusion that failed to satisfy the separate-statement requirement.
New Trial Motion Amends Conclusions
Lila Lin prevailed in a nonjury trademark trial. Legacy Motors moved for a new trial under Rule 59 and asked the court to revise its legal conclusion that the mark was generic. The court reopened the record, amended the conclusion, and entered a new judgment.
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Statutes
Federal Rules
Restatements
Casebooks
Dictionaries
Leonard Lowe was charged with arson. The trial judge instructed the jury that the presumption of innocence is merely a legal conclusion rather than evidence. The appellate court reversed because the instruction mischaracterized the presumption as an instrument of proof.
Davis v. United States160 U.S. 469, 16 S.Ct. 353, 40 L.Ed. 499 (1895)
Apportionment Claim Dismissal
Lena Lawson challenged a state legislative map as unconstitutional. Her complaint alleged only that the districts were arbitrary and obsolete. The court dismissed because those bare assertions were legal conclusions that supplied no factual basis for relief.
Baker v. Carr369 U.S. 186, 211
Pleading Insufficiency Ruling
Lighthouse Shipping sued Linden Logistics alleging an antitrust conspiracy. The complaint recited only that the defendants had conspired without facts showing agreement. The court dismissed because the allegation was a legal conclusion that failed to state a plausible claim.
Bell Atlantic Corp. v. Twombly550 U.S. 544, 556, 127 S.Ct. 1955, 167 L. Ed. 2d 929 (2007)
Administrative Findings Review
Lumen Capital challenged an agency compensation order. The district court reviewed the agency's legal conclusion de novo while accepting its factual findings. The Supreme Court upheld the distinction between the two categories of determinations.
Crowell v. Benson285 U.S. 22 (1932)
Common questions
Frequently Asked
5
How does a legal conclusion differ from a finding of fact?+
A legal conclusion states a duty or result without supporting facts. A finding of fact rests on evidence presented at trial. Courts must separate the two under Rule 52(a)(1) so that appellate review can apply the correct standard to each.
Supporting sources
Are legal conclusions accepted as true on a motion to dismiss?+
No. Threadbare recitals of the elements of a cause of action supported only by conclusory statements do not suffice. Courts are not bound to accept a legal conclusion couched as a factual allegation.
Supporting sources
What happens when a court issues only legal conclusions after a bench trial?+
The judgment may be reversed or remanded because Rule 52(a)(1) requires the court to find facts specially and state conclusions of law separately. Sparse statements that merely announce liability prevent meaningful appellate review.
Supporting sources
Can a court amend legal conclusions on a Rule 59 motion?+
Yes. After a nonjury trial the court may open the judgment, take additional testimony, amend findings of fact and conclusions of law, and direct entry of a new judgment.
Supporting sources
How are legal conclusions treated in administrative proceedings?+
A bankruptcy judge or magistrate submits proposed findings and conclusions to the district court, which reviews legal conclusions de novo. The district judge enters the final order after independent review of objected-to conclusions of law.
Supporting sources
369 U.S. 186, 211Constitutional Law
…existing Tennessee apportionment is "incorrect," "arbitrary," "obsolete" and "unconstitutional"amounting to nothing more than legal conclusionsdo not themselves save the complaint from dismissal. See Snowden v. Hughes , 321 U. S. 1; Collins v. Hardyman , 341 U. S. 651. Nor do those allegations shift to the appellees the…