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Rule 801.Findings and Conclusions by the Court

Part VIII. Judgments; Post-Decree and Post-Judgment Proceedings · Last amended July 1, 2021 · Last verified September 4, 2026

In one sentenceRule 801 requires the court to find facts specifically and state conclusions of law separately after trial, and gives 14 days to move to amend or add findings.

Full Text of Rule 801

Text sizeJump to: (a) (b) (c)

(a) In General.
(1) After Trial. The court must find specific facts and state its conclusions of law separately. The findings and conclusions may be stated on the record after the close of the evidence or may appear in an opinion or a memorandum of decision filed by the court. Judgment must be entered under Rule 802.
(2) Interlocutory Injunction. In granting or refusing an interlocutory injunction, the court must similarly state the findings and conclusions that support its action.
(3) Judgment by Default. The court is not required to state findings or conclusions in support of a judgment by default.
(4) Motion. The court is not required to state findings or conclusions when ruling on an interlocutory order, a motion under Rules 502 or 507, or any other motion except as provided in Rule 119.
(5) Effect of a Master's Findings. A master's findings, to the extent adopted by the court, must be considered the court's findings.
(6) Questioning 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.
(7) Setting Aside 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 court's opportunity to judge the witnesses' credibility.
(b) Amendment or Additional Findings. On a party's motion filed no later than 14 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 804.
(c) Assignment of Error. No party may assign as error the lack of findings unless the party raised the issue to the court by an appropriate motion.
End

Rule History

(Adopted March 29, 2021, effective July 1, 2021.)

Plain-English Summary

Rule 801 is the rule that makes a family law decision reviewable.

After trial

The court must find specific facts and state its conclusions of law separately. They may be stated on the record after the close of the evidence, or appear in an opinion or memorandum decision. Judgment is then entered under Rule 802.

The same duty applies to granting or refusing an interlocutory injunction.

Where findings are not required

Not for a judgment by default. Not when ruling on an interlocutory order, on a motion under Rule 502 (evidence on motions) or Rule 507 (summary judgment), or on any other motion except as Rule 119 provides.

A master's findings, to the extent the court adopts them, must be considered the court's findings — which is why Rule 1006(g)(2) allows written objections within 14 days of the report.

Two review provisions

Subsection (a)(6) removes a trap: a party may later question the sufficiency of the evidence supporting the findings whether or not it requested findings, objected to them, moved to amend them, or moved for partial findings. Sufficiency is preserved without any post-trial motion.

And the standard: findings must not be set aside unless clearly erroneous, with the reviewing court giving due regard to the trial court's opportunity to judge the witnesses' credibility. In a case decided on competing accounts from two parents, that is a heavy deference.

Amending or adding findings

On a motion filed no later than 14 days after entry of judgment, the court may amend its findings, make additional findings, and amend the judgment accordingly. The motion may accompany a Rule 804 motion for a new trial.

Rule 104(b)(3) forbids extending that deadline, and Rule 503(b)(2) forbids moving to reconsider the ruling on it.

The one thing a motion is needed for

Subsection (c): no party may assign as error the lack of findings unless it raised the issue to the court by an appropriate motion. Sufficiency of the findings survives silence; their absence does not. If the court did not make a finding you needed, ask for it within the 14 days or the point is gone.

Frequently Asked Questions

Does the judge have to explain the decision?

After trial, yes. Rule 801(a)(1) requires the court to find specific facts and state its conclusions of law separately, stated on the record after the close of the evidence or in an opinion or memorandum of decision.

How long do I have to ask for additional findings?

Rule 801(b) requires the motion to be filed no later than 14 days after the entry of judgment, and allows it to accompany a motion for a new trial under Rule 804.

Do I have to object to preserve a sufficiency challenge?

No. Rule 801(a)(6) allows a party to 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.

What if the court simply did not make a finding I needed?

Then a motion is required. Rule 801(c) provides that no party may assign as error the lack of findings unless the party raised the issue to the court by an appropriate motion.

What standard applies to findings on appeal?

Rule 801(a)(7) provides that findings of fact must not be set aside unless clearly erroneous, and requires the reviewing court to give due regard to the trial court's opportunity to judge the witnesses' credibility.

Are findings required on a summary judgment motion?

No. Rule 801(a)(4) provides that the court is not required to state findings or conclusions when ruling on an interlocutory order, a motion under Rules 502 or 507, or any other motion except as provided in Rule 119.

Source & verification. Rule text and Rule History reproduced verbatim from the Idaho Rules of Family Law Procedure as published by the Idaho Supreme Court, current through amendments effective July 1, 2026. Promulgated by the Supreme Court of Idaho (Idaho Const. art. V, sec. 25). Last verified September 4, 2026. · Official text
Also known as: findings of factconclusions of lawclearly erroneous14 daysadditional findingsmemorandum decisionsufficiency of the evidence