Title VI: Alternative Dispute Resolution and Trial · Last amended July 1, 2016 · Last verified July 14, 2026
In one sentenceRule 52 requires a judge trying a civil case without a jury to find the facts and state conclusions of law separately, gives a party 14 days after judgment to ask for amended or additional findings, and tells a reviewing court to leave those findings alone unless they are clearly erroneous.
(1)For actions tried without a jury. 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 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 58. A party may raise the question of the sufficiency of the evidence to support the findings whether or not the party raising the question has made an objection to the findings or a motion to amend them or a motion for judgment.
(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)Judgment by default. The court is not required to state findings or conclusions in support of a judgment by default.
(4)For a motion. The court is not required to state findings or conclusions when ruling on an interlocutory order made pursuant to a show cause hearing or on a motion under Rule 12 or 56 or, unless these rules provide otherwise, on any other motion.
(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 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.
(7)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 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 59.
(c)Assignment of error. No party may assign as error the lack of findings unless the party raised the issue to the trial court by an appropriate motion.
Amendment History
(Adopted March 1, 2016, effective July 1, 2016.)
Plain-English Summary
Rule 52 governs what a judge owes the parties after a bench trial. The court has to find the facts specially and state its legal conclusions separately, whether that happens on the record right after the evidence closes or in a written opinion or memorandum decision. The same obligation applies when the court grants or denies an interlocutory injunction. A few situations are exempt: the court does not need to explain a default judgment, and it does not need findings when ruling on an interlocutory order from a show-cause hearing, a Rule 12 or Rule 56 motion, or most other motions. When a master's findings get adopted by the court, they count as the court's own findings for these purposes. Whatever the court decides, a party can challenge the sufficiency of the evidence behind the findings later, regardless of whether that party objected to the findings, moved to amend them, or asked for judgment at trial.
After judgment, a party has 14 days to move the court to amend its findings, add findings it left out, or amend the judgment to match — a motion that can ride along with a Rule 59 motion for a new trial. On appeal, the findings themselves get real deference: they cannot be set aside unless clearly erroneous, and the reviewing court has to give weight to the trial judge's firsthand chance to assess witness credibility. That deference has one procedural condition — a party cannot argue on appeal that the trial court failed to make necessary findings unless that argument was first raised in the trial court through an appropriate motion.
Frequently Asked Questions
Does a judge have to explain a ruling in writing after a bench trial?
Yes. Rule 52(a)(1) requires the court to find the facts specially and state its conclusions of law separately, whether on the record after the evidence closes or in a filed opinion or memorandum decision.
What is the "clearly erroneous" standard, and why does it matter?
It is the standard an appellate court applies to a trial judge's factual findings after a bench trial: the findings stand unless the reviewing court is left with a definite conviction they were wrong. Because the trial judge saw the witnesses testify, the appellate court gives real weight to the judge's credibility calls rather than reweighing the evidence itself.
How do I ask a judge to amend or add findings after a bench trial?
File a motion no later than 14 days after entry of judgment asking the court to amend its findings, make additional findings, or amend the judgment to match. This motion can be combined with a motion for a new trial under Rule 59.
Does the court have to make findings on a default judgment or when ruling on a motion?
No. Rule 52(a)(3) and (a)(4) exempt default judgments and rulings on interlocutory show-cause orders, Rule 12 or Rule 56 motions, and most other motions from the findings requirement, unless another rule says otherwise.
Can I challenge the sufficiency of the evidence on appeal even if I didn't object to the findings at trial?
Yes, for the sufficiency of the evidence itself — Rule 52(a)(1) and (a)(6) preserve that challenge regardless of whether a party objected to the findings, moved to amend them, or moved for judgment. But challenging the absence of findings altogether requires having raised that specific issue in the trial court first.
Source & verification. Rule text
are reproduced verbatim from the Idaho Rules of Civil Procedure, adopted by the
Supreme Court of Idaho. Last verified July 14, 2026. ·
Official source
Also known as:idaho findings of fact and conclusions of law ruleclearly erroneous standard idahobench trial findings idaho civil rule 52amending findings after bench trial idaho