More facts found, about findings

Originally published by David Coale.

Adding to the Fifth Court’s thorough discussion of exactly what constitutes a “finding of fact” in In re AEJ, the Court recently reminded: “Though the parties’ appellate arguments describe oral ‘findings’ recited by the trial court, a trial
court’s oral statements from the bench do not generally constitute findings of fact. ‘Statements made by a trial court outside of properly filed written
findings and conclusions do not limit an appellate court’s review.’” WorldVentures Marketing v. Travel to Freedom, No. 05-20-00169-CV (Sept. 23, 2020) (mem. op.) (citations omitted).

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