K.S.A. 60-252.Findings and conclusions by the court; judgment on partial findings
Last amended July 1, 2010 · Last verified July 28, 2026
In one sentenceKansas Rule 60-252 requires a judge in a bench trial, advisory-jury trial, or summary-judgment ruling to state findings of fact and conclusions of law separately, and lets the court enter judgment against a party on a dispositive issue before all the evidence is in.
(1)In general. In an action tried on the facts without a jury or with an advisory jury or upon entering summary judgment, 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 evidence, or may appear in an opinion or a memorandum of decision filed by the court. Judgment must be entered under K.S.A. 60-258, and amendments thereto.
(2)For an interlocutory injunction. In granting or refusing an interlocutory injunction, except in divorce cases, the court must similarly state the findings and conclusions that support its action.
(3)Effect of a master's findings. A master's findings, to the extent adopted by the court, must be considered the court's findings.
(4)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 judgment on partial findings.
(5)Setting aside the findings. Findings of fact 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 witness' 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 K.S.A. 60-259, and amendments thereto.
(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 subsection (a).
Amendment History
L. 1963, ch. 303, 60-252; amended by Supreme Court order dated July 28, 1976; L. 1997, ch. 173, § 27; L. 2010, ch. 135, § 123; July 1.
Plain-English Summary
Subsection (a) requires a court trying a case without a jury, with an advisory jury, or entering summary judgment, to find the facts specially and state its conclusions of law separately. The court can put those findings on the record after evidence closes or set them out in an opinion or memorandum, and judgment then follows under K.S.A. 60-258. The same obligation applies when the court grants or refuses an interlocutory injunction, except in divorce cases, and a master's findings that the court adopts count as the court's own findings.
A party can question whether the evidence supports the findings later, whether or not that party asked for findings, objected to them, or moved to amend, and the findings themselves can't be set aside unless clearly erroneous — with a reviewing court giving weight to the trial court's chance to judge witness credibility firsthand.
Subsection (b) gives a party 28 days after judgment is entered to move for amended or additional findings, and the court can amend the judgment to match; this motion can travel alongside a new-trial motion under K.S.A. 60-259.
Subsection (c) covers judgment on partial findings: if a party has been fully heard on an issue in a nonjury trial and the court finds against that party on it, the court can enter judgment on any claim or defense that turns on that issue, without waiting for the rest of the evidence — though it can also choose to wait until the evidence closes. Any judgment entered this way still needs the same findings and conclusions subsection (a) requires.
Frequently Asked Questions
When must a Kansas judge state findings of fact and conclusions of law separately?
In an action tried without a jury, with an advisory jury, or upon entering summary judgment. The findings can go on the record after evidence closes or appear in a written opinion or memorandum.
Can I challenge the evidence behind a judge's findings even if I never objected to them at trial?
Yes. Subsection (a)(4) lets a party question the sufficiency of the evidence supporting the findings later, regardless of whether the party requested findings, objected, or moved to amend them.
What standard applies on appeal to a Kansas judge's findings of fact?
Findings of fact must not be set aside unless clearly erroneous, and the reviewing court gives due regard to the trial court's opportunity to judge witness credibility.
How long do I have to ask the court to amend or add to its findings?
28 days after the entry of judgment. The motion can be filed together with a motion for a new trial under K.S.A. 60-259.
What is a judgment on partial findings under 60-252(c)?
It lets a court, in a nonjury trial, enter judgment against a party on a claim or defense once that party has been fully heard on a dispositive issue and the court rules against them on it — even before all the evidence has been presented, though the court may choose to wait.
Source & verification. Section text is reproduced verbatim from the
Kansas Statutes Annotated, enacted by the Kansas Legislature. Last verified July 28, 2026.
· Official source
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