/STAYT-muhnt of FIND-ings and kuhn-KLOO-zhuhns/·procedural term
Also known as:statements of findings and conclusions · findings and conclusions
Written by attorneys · grounded in primary & secondary sources — see below
A court's required articulation of its factual determinations and legal reasoning in support of a decision in a nonjury trial or when granting or refusing an interlocutory injunction. The statement enables parties to understand the basis for the ruling and permits effective appellate review under the clearly erroneous standard.
Sources & Authorities· 5 primary sources
Select any source to read its text and confirm it supports the definition.
Statutes
Federal Rules
Hornbooks
How it applies
Common Examples
6
Bench Trial on Contract Claims
Sofia Stern sued Stonehaven Properties in federal court for breach of a commercial lease after a bench trial. The district judge announced from the bench that the landlord had breached the covenant of quiet enjoyment and entered judgment for Sofia. Because the court failed to state its factual findings on the extent of interference or its legal conclusion applying the covenant, the court of appeals vacated the judgment and remanded for a proper statement of findings and conclusions.
Denial of Preliminary Injunction
Silverline Industries moved for a preliminary injunction to halt Sierra Solutions from marketing a competing product. After an evidentiary hearing the district judge denied the motion in a one-sentence docket entry citing deference to agency expertise. Silverline appealed, and the court of appeals vacated the denial because the district court had not stated the findings of fact and conclusions of law supporting its refusal of interlocutory relief.
Administrative Census Decision
Stephen Shaw challenged the Department of Commerce's decision to add a citizenship question to the census. The district court reviewed the administrative record and issued a detailed statement explaining its factual findings on the secretary's rationale and its legal conclusion that the decision violated the Administrative Procedure Act. The Supreme Court relied on that statement to evaluate whether the agency's action was arbitrary and capricious.
Department of Commerce v. New York588 U.S. 752 (2019)
Due Process Property Interest
Simon Stern, a college instructor, sued after his contract was not renewed. The district court made findings that the college's policies created a legitimate expectation of continued employment and concluded that the lack of a hearing violated due process. The Supreme Court affirmed the judgment on the basis of those findings and conclusions.
Perry v. Sindermann408 U.S. 593 (1972)
Medical License Revocation Hearing
Sarah Sullivan, a physician, challenged the revocation of her license by a state medical board. The district court reviewed the hearing officer's statement of findings and conclusions and determined that the board's procedures satisfied due process. The Supreme Court upheld the procedures because the statement adequately disclosed the factual basis and legal standards applied.
Withrow v. Larkin421 U.S. 35 (1975)
Agency Rulemaking Record
Stella Shapiro and the Sierra Club challenged an EPA regulation on air quality standards. The D.C. Circuit examined the agency's statement of findings and conclusions in the rulemaking record and concluded that the agency had adequately explained its policy choices and responded to comments. The court therefore upheld the regulation.
Sierra Club v. Costle657 F.2d 298, 406 (D.C. Cir. 1981)
Common questions
Frequently Asked
5
When must a federal district court provide a statement of findings and conclusions?+
A federal district court must provide a statement of findings and conclusions after a nonjury trial on the facts and when granting or refusing an interlocutory injunction. The requirement does not apply to rulings on motions under Rules 12 or 56 or most other motions.
Supporting sources
Does the requirement apply to the denial of a preliminary injunction?+
Yes. When a court grants or refuses an interlocutory injunction, including a preliminary injunction, it must state the findings and conclusions that support its action. The obligation exists whether the court grants or denies the relief so that the parties and any reviewing court can understand the basis for the decision.
Supporting sources
Is a one-sentence docket entry sufficient when denying a temporary restraining order?+
No. A bare docket entry that merely references deference to agency expertise or states only that the motion is denied fails to satisfy the requirement to state supporting findings and conclusions. The court must articulate the factual determinations and legal analysis so that the parties and appellate court can evaluate whether the injunction factors were properly applied.
Supporting sources
What is the remedy when a district court fails to provide adequate findings on an injunction motion?+
The usual remedy is for the court of appeals to vacate the order and remand so that the district court can make and state proper findings and conclusions. The appellate court does not ordinarily decide the injunction request in the first instance or reverse outright on the merits.
Supporting sources
Does Rule 52 require findings when a court rules on a motion for summary judgment?+
No. Rule 52(a)(3) expressly provides that a court need not state findings or conclusions when ruling on a motion under Rule 56. The exemption applies even when the underlying case involves complex claims.
Supporting sources
findings and conclusions
has greatly complicated the task of the Board and has made it virtually impossible in some instances to know whether particular issues are in fact contested.” App. 190 n. 10. The Appeal…
of its
findings and conclusions
. 38 U.S.C. § 4004(d). The fee limitation at issue in this case is part of a comprehensive statutory scheme that governs the provision of benefits to veterans. The scheme is designed to…
Civil ProcedureMotions · Posttrial motions, including motions for relief from judgment and for new trialUBEIntermediate