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Rule 52.Findings by the Court

Last amended July 1, 2015 · Last verified July 1, 2026

In one sentenceRule 52 lets a party request written findings of fact and separate conclusions of law whenever a case is tried to the court without a jury, and treats a timely opinion or memorandum of decision containing both as satisfying that request.

Full Text of Rule 52

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When questions of fact are tried by the court without a jury, judgment may be general for the prevailing party unless one of the parties in writing requests otherwise before the entry of judgment pursuant to Civ.R. 58, or not later than seven days after the party filing the request has been given notice of the court's announcement of its decision, whichever is later, in which case, the court shall state in writing the findings of fact found separately from the conclusions of law.
When a request for findings of fact and conclusions of law is made, the court, in its discretion, may require any or all of the parties to submit proposed findings of fact and conclusions of law; however, only those findings of fact and conclusions of law made by the court shall form part of the record.
Findings of fact and conclusions of law required by this rule and by Civ.R. 41(B)(2) and Civ.R. 23(G)(3) are unnecessary upon all other motions including those pursuant to Civ.R. 12, Civ.R. 55 and Civ.R. 56.
An opinion or memorandum of decision filed in the action prior to judgment entry and containing findings of fact and conclusions of law stated separately shall be sufficient to satisfy the requirements of this rule and Civ.R. 41(B)(2).

Amendment History

Effective Date: July 1, 1970

Amended: July 1, 1971; July 1, 1989; July 1, 2015

Staff Note (July 1, 2015 Amendment)

The rule is amended to (1) replace “conclusions of fact” with “findings of fact” in the first paragraph of the rule and (2) include a reference to the findings of fact and conclusions of law required by Civ.R. 23(G)(3).

Plain-English Summary

When questions of fact are tried by the court without a jury, judgment may be general for the prevailing party unless a party requests otherwise in writing, either before the entry of judgment or within seven days after the party has been given notice of the court's announcement of its decision, whichever comes later. Once that request is timely made, the court must state its findings of fact separately from its conclusions of law, either as part of the judgment or in a separate document. An opinion or memorandum of decision filed before judgment that already contains separately stated findings and conclusions satisfies this requirement without any further filing. When a party requests findings, the court may, in its discretion, require any or all of the parties to submit proposed findings of fact and conclusions of law, though only what the court itself adopts becomes part of the record. Findings of fact and conclusions of law are not required for rulings on other motions, including those under Rules 12, 55, and 56.

Frequently Asked Questions

How does a party get the court to explain its factual findings after a bench trial?

By requesting findings of fact and conclusions of law in writing, either before judgment is entered or within seven days after the party is notified of the court's decision, whichever is later.

Does a written opinion count as findings of fact and conclusions of law?

Yes, if it's filed before the judgment entry and separately states the findings of fact and conclusions of law, it satisfies Rule 52 without any additional filing.

Are findings of fact required when the court rules on a motion rather than after a full trial?

No. Rule 52 doesn't require findings of fact and conclusions of law for rulings on other motions, including motions under Rules 12, 55, and 56.

Source & verification. The rule text, Effective Date, Amended dates, and Staff Notes are reproduced verbatim from the official Ohio Rules of Civil Procedure (Ohio R. Civ. P. 52). Prescribed by the Supreme Court of Ohio (Ohio Constitution, Art. IV, § 5(B)). The plain-English summary is original and written by us. Last verified July 1, 2026. · Official source
Also known as: findings of fact and conclusions of lawbench trial findings