52.01 Effect In all actions tried upon the facts without a jury or with an advisory jury, the court shall find the facts specially and state separately its conclusions of law thereon and direct the entry of the appropriate judgment; and in granting or refusing interlocutory injunctions the court shall similarly set forth the findings of fact and conclusions of law which constitute the grounds for its action. Requests for findings are not necessary for purposes of review. Findings of fact, whether based on oral or documentary evidence, shall not be set aside unless clearly erroneous, and due regard shall be given to the opportunity of the trial court to judge the credibility of the witnesses. The findings of a referee, to the extent adopted by the court, shall be considered as the findings of the court. It will be sufficient if the findings of fact and conclusions of law are stated orally and recorded in open court following the close of the evidence or appear in an opinion or memorandum of decision filed by the court or in an accompanying memorandum. Findings of fact and conclusions of law are unnecessary on decisions on motions pursuant to Rule 12 or 56 or any other motion except as provided in Rules 23.08(c) and 41.02.
Rule 52.Findings by the Court
Last amended March 1, 2001 · Last verified July 1, 2026
In one sentenceRule 52 requires a judge deciding a case without a jury to make separate written or oral findings of fact and conclusions of law, which an appeals court will not disturb unless clearly wrong.
Full Text of Rule 52
52.02 Amendment Upon motion of a party served and heard not later than the time allowed for a motion for new trial pursuant to Rule 59.03, the court may amend its findings or make additional findings, and may amend the judgment accordingly if judgment has been entered. The motion may be made with a motion for a new trial and may be made on the files, exhibits, and minutes of the court. When findings of fact are made in actions tried by the court without a jury, the question of the sufficiency of the evidence to support the findings may thereafter be raised whether or not the party raising the question has made in the district court an objection to such findings or has made a motion to amend them or a motion for judgment.
Advisory Committee Comments
Advisory Committee Comment--2000 Amendments
Although the text of this Rule 52.02 is not changed substantively by these amendments, it is worth noting that Rule 59.03, governing the time for filing a motion for a new trial is changed to expand the time from 15 days to 30 days for filing motion and from 30 days to 60 days for having the motion heard. This amendment has the practical effect of extending the time for filing a motion for amended findings under Rule 52 because Rule 52.02 incorporates the filing and hearing time limits of Rule 59.
Amendment History
- (Amended effective March 1, 2001.)
Plain-English Summary
When a case is tried to the court instead of a jury, or tried with an advisory jury, the judge has to find the facts specifically and state legal conclusions separately, then direct entry of the appropriate judgment. The same requirement applies when a judge grants or denies an interlocutory injunction. Neither side has to formally request findings in order to preserve the right to challenge them later. The findings can be delivered in different ways: stated orally on the record right after the evidence closes, or written out in an opinion, memorandum of decision, or accompanying memorandum.
Once findings are made, they carry real weight on appeal. A finding of fact will not be overturned unless it is clearly erroneous, and an appellate court has to give real deference to the trial judge’s chance to observe witnesses and judge their credibility firsthand. If a referee’s findings are adopted by the court, those findings count as the court’s own findings. Findings and conclusions are not required, however, when a court rules on a motion to dismiss or for summary judgment, or most other motions, except in the specific situations the rule identifies.
After findings are made, a party can ask the judge to amend or add to them, or to amend the judgment if one has already been entered. That motion has to be served and heard within the same time allowed for a new trial motion, and can be combined with a new trial motion. A party can also challenge whether the evidence was sufficient to support the findings later on, whether or not that party objected to the findings or moved to amend them in the trial court.
Frequently Asked Questions
Does a judge have to explain the reasoning behind a bench trial decision?
Yes, in any 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, and direct entry of the appropriate judgment.
Do I have to ask the judge to make findings in order to challenge them later?
No, requests for findings are not necessary for purposes of review.
How hard is it to overturn a trial judge’s factual findings on appeal?
Findings of fact will not be set aside unless clearly erroneous, and the appellate court must give due regard to the trial court’s opportunity to judge witness credibility.
Can I ask the judge to change the findings after they are issued?
Yes, on a motion served and heard no later than the time allowed for a new trial motion under Rule 59.03, the court may amend its findings or make additional findings, and may amend the judgment accordingly.
Do I need findings and conclusions after a summary judgment ruling?
No, findings of fact and conclusions of law are unnecessary on decisions on motions under Rule 12 or 56, or on most other motions, except as specifically provided in Rules 23.08(c) and 41.02.
Source & verification. The rule text and Advisory Committee Comments are reproduced verbatim from the
official Minnesota Rules of Civil Procedure (Minn. R. Civ. P. 52). Prescribed by the Supreme Court of Minnesota (Minn. Stat. § 480.051). The plain-English summary is original and written by us. Last verified July 1, 2026. ·
Official source
Also known as: bench trial findingsfindings of fact and conclusions of law
Advisory Committee Comment—2006 Amendment
Rule 52.01 is amended to renumber one of the rule cross-references to reflect the amendment and renumbering of Rule 23 as part of the amendments effective January 1, 2006.