52.01 Findings Required. In all actions tried upon the facts without a jury, the court shall find the facts specially and shall state separately its conclusions of law and direct the entry of the appropriate judgment. The findings of a master, to the extent that the court adopts them, shall be considered as the findings of the court. If an opinion or memorandum of decision is filed, it will be sufficient if the findings of fact and conclusions of law appear therein. Findings of fact and conclusions of law are unnecessary on decisions of motions under Rule 12 or 56 or any other motion except as provided in Rules 41.02 and 65.04(6).
Rule 52.Findings by the Court
Last verified July 2, 2026
In one sentenceRule 52 requires a court trying a case without a jury to find the facts specially and state its legal conclusions separately, treats an adopted master’s findings as the court’s own, excuses findings on most pretrial motions, and lets a party move within 30 days after judgment to amend or add findings.
Full Text of Rule 52
52.02 Amendment. Upon motion of a party made not later than thirty (30) days after entry of judgment the court may amend its findings or make additional findings and may amend the judgment accordingly. The motion may be made with a motion for a new trial pursuant to Rule 59. 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 be raised on appeal whether or not the party raising the question has made in the trial court an objection to such findings or has made a motion to amend them or a motion for judgment.
Advisory Commission Comments
Plain-English Summary
Rule 52.01 requires a court deciding a case without a jury to find the facts specially and state its conclusions of law separately, then direct entry of the judgment those findings and conclusions support. The findings do not have to take any particular form — an opinion or memorandum of decision satisfies the rule as long as the factual findings and legal conclusions appear in it — but the document has to make clear whether it is the judgment itself or just the reasoning behind a judgment entered separately, since ambiguity on that point is a common source of appellate confusion. When the court adopts a special master’s findings, those findings count as the court’s own for purposes of this rule. Findings and conclusions are not required when the court rules on a Rule 12 or Rule 56 motion, or on most other motions, with a short list of exceptions written into the rule itself.
Because findings let an appellate court trace how the trial court reached its result, Tennessee courts expect more detail in cases where the reasoning behind a discretionary call matters most — cases terminating parental rights, custody and visitation disputes, and punitive damages awards, where each statutory factor the court considered typically needs its own discussion. A court can ask the prevailing party to draft proposed findings, but only after the court has stated its own grounds for the ruling; asking a party to draft findings without first stating those grounds, and then adopting the draft largely unchanged, invites the appearance of a rubber-stamped decision the rule is meant to guard against.
Rule 52.02 gives a party 30 days after judgment to move the court to amend its findings or make additional ones, and to amend the judgment to match. That motion can be combined with a motion for a new trial under Rule 59. A party does not have to have objected to the findings at trial, or moved to amend them, before challenging the sufficiency of the evidence supporting them on appeal — that challenge survives on its own regardless of what happened in the trial court.
Frequently Asked Questions
Does a judge have to explain the reasoning behind a nonjury verdict?
Yes. Rule 52.01 requires the court to find the facts specially and state its legal conclusions separately in any case tried without a jury, then direct entry of the judgment those findings support.
Do I have to object to the court’s findings at trial to challenge them on appeal?
No. Rule 52.02 lets a challenge to the sufficiency of the evidence supporting the findings proceed on appeal whether or not the party raised an objection or moved to amend the findings in the trial court.
Does a court have to make findings when ruling on a motion to dismiss or for summary judgment?
Source & verification. The rule text and Advisory Commission Comments are reproduced verbatim from the
official Tennessee Rules of Civil Procedure (Tenn. R. Civ. P. 52). Prescribed by the Supreme Court of Tennessee (Tenn. Code Ann. §§ 16-3-402 to 16-3-407, 16-3-601). The plain-English summary is original and written by us. Last verified July 2, 2026. ·
Official source
Also known as: findings of fact and conclusions of lawbench trial findingsmotion to amend findings
Advisory Commission Comments.
This Rule conforms generally to Tenn. Code Ann. § 27-1-113.