Rule 52.Findings and Conclusions by the Court; Judgment on Partial Findings
Group VI: Trials · Last amended 2017 · Last verified July 14, 2026
In one sentenceRule 52 requires a Superior Court judge trying a civil case without a jury to state separate findings of fact and conclusions of law, protects those findings from reversal unless clearly erroneous, and lets the judge enter judgment against a party on an issue once that party has been fully heard and has lost the point that controls a claim or defense.
(1)In General. Unless expressly waived by all parties, in an action tried on the facts without a jury or with an advisory jury, the court must find the facts specially and state its conclusions of law separately. The findings and conclusions may be stated on the record or may appear in an opinion or a memorandum of decision filed by the court and are sufficient if they state the controlling factual and legal grounds of decision. Judgment must be entered under Rule 58.
(2)For an Interlocutory Injunction. In granting or refusing an interlocutory injunction, the court must similarly state the findings and conclusions that support its action.
(3)For a Motion. The court is not required to state findings or conclusions when ruling on a motion under Rule 12 or 56 or, unless these rules provide otherwise, on any other motion.
(4)Effect of a Master’s Findings. A master’s findings, to the extent adopted by the court, must be considered the court’s findings.
(5)Questioning the Evidentiary Support. A party may later question the sufficiency of the evidence supporting the findings, whether or not the party requested findings, objected to them, moved to amend them, or moved for partial findings.
(6)Setting Aside the Findings. Findings of fact, whether based on oral or other evidence, must not be set aside unless clearly erroneous, and the reviewing court must give due regard to the trial court’s opportunity to judge the witnesses’ credibility.
(b)AMENDED OR ADDITIONAL FINDINGS. On a party's motion filed no later than 28 days after the entry of judgment, the court may amend its findings—or make additional findings—and may amend the judgment accordingly. The motion may accompany a motion for a new trial under Rule 59.
(c)JUDGMENT ON PARTIAL FINDINGS. If a party has been fully heard on an issue during a nonjury trial and the court finds against the party on that issue, the court may enter judgment against the party on a claim or defense that, under the controlling law, can be maintained or defeated only with a favorable finding on that issue. The court may, however, decline to render any judgment until the close of the evidence. A judgment on partial findings must be supported by findings of fact and conclusions of law as required by Rule 52(a).
Comments
2017 Amendments:
This rule is substantially similar to Federal Rule of Civil Procedure 52, as amended in 2007 and 2009, but maintains the following local distinctions in subsection (a)(1): 1) the parties can expressly waive the requirement that the court state its findings of fact and conclusions of law in a nonjury action; 2) the phrase “after the close of evidence” has been deleted to permit the court to make partial findings and conclusions as the case progresses; and 3) the findings and conclusions need only state the controlling grounds for the decision.
Consistent with the federal rule, the 10-day deadline for parties to file post-judgment motions has been expanded to 28 days. This was necessitated by the Rule 6(b) prohibition on an extension of this deadline. The change is intended to give parties more time to prepare a satisfactory post-judgment motion while maintaining certainty in appeal times.
Comment:
Identical to Federal Rule of Civil Procedure 52 except that section (a) has been revised to eliminate the requirement of stating findings of facts and conclusions of law in non-jury actions where the necessity of making the same is expressly waived by the parties and to indicate that such findings and conclusions may be written or oral and need only state the controlling grounds of decision. These provisions are necessitated by the time demands of a massive volume of litigation and are designed to insure that all litigants who desire it receive a fair and adequate statement of the grounds of decision applied in their case while at the same time making clear that such statements of fact and law need not be unduly lengthy nor presented in written form if the Court prefers to dictate them from the bench.
Plain-English Summary
Rule 52(a) requires that in a case tried on the facts without a jury, or with only an advisory jury, the court find the facts specially and state its legal conclusions separately, unless every party expressly waives that requirement. Those findings and conclusions can appear on the record, in an opinion, or in a memorandum of decision, and they're sufficient as long as they cover the controlling factual and legal grounds — the court doesn't need to address every argument raised. The same obligation applies when the court grants or denies an interlocutory injunction. On the other hand, the court doesn't have to state findings when ruling on a motion under Rule 12 or Rule 56, or on most other motions, unless another rule says otherwise.
A master's findings, once the court adopts them, count as the court's own findings under this rule. A party can question whether the evidence supports the findings later on, whether or not that party asked for findings, objected to them, or moved to amend them beforehand. When a challenge does come, Rule 52(a)(6) sets the bar high: findings of fact stand unless clearly erroneous, and a reviewing court has to give real weight to the trial judge's chance to observe the witnesses and judge their credibility.
Rule 52(b) lets a party ask the court to amend its findings, or add to them, and to adjust the judgment accordingly, on a motion filed no later than 28 days after judgment is entered — a motion that can travel alongside a Rule 59 new-trial motion. Rule 52(c) then gives the nonjury trial its own counterpart to a directed verdict: once a party has been fully heard on an issue and the court rules against that party on it, the court can enter judgment on any claim or defense that, under the controlling law, depends on a favorable finding on that same issue. The court doesn't have to act right away — it can wait until the evidence closes — but whenever it does enter that judgment, the judgment still needs the supporting findings and conclusions Rule 52(a) requires.
Frequently Asked Questions
Do I need to ask the court for findings of fact after a bench trial?
No. Rule 52(a)(1) requires the court to state its findings of fact and conclusions of law on its own, unless every party has expressly waived that requirement.
Can the judge state findings and conclusions out loud instead of writing a formal opinion?
Yes. Rule 52(a)(1) allows the findings and conclusions to be stated on the record, in an opinion, or in a memorandum of decision, and they need only cover the controlling factual and legal grounds of the decision.
How do I challenge the judge's factual findings on appeal?
Rule 52(a)(6) sets a clearly-erroneous standard, and the reviewing court gives real weight to the trial judge's opportunity to assess witness credibility. You can question the sufficiency of the evidence even if you didn't object to the findings when they were made.
How long do I have to ask the court to amend or add to its findings?
No later than 28 days after judgment is entered, under Rule 52(b). That motion can be filed together with a motion for a new trial under Rule 59.
Can the judge rule against me on part of my case before the trial is over?
Yes. Rule 52(c) lets the court enter judgment against a party once that party has been fully heard on a controlling issue in a nonjury trial and the court rules against it, though the court may choose to wait until the evidence closes. That judgment still needs the findings and conclusions Rule 52(a) requires.
Source & verification. Rule text and official Comments are
reproduced verbatim from the District of Columbia Superior Court Rules of Civil
Procedure, adopted by the Superior Court of the District of Columbia. Last verified July 14, 2026.
· Official source
Also known as:dc findings of fact and conclusions of lawbench trial findings dc superior courtjudgment on partial findings dcclearly erroneous standard dc rule 52