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That lawsuit went to a bench trial and resulted in judgment for the electrician. Afterward, the homeowner's attorney wanted to determine what, if any, preclusionary effect the judgment would have. After asking his associate to pull the judgment from the files, the homeowner's attorney was surprised to find that the only words written on the judgment were «judgment for the electrician.»
Two years ago, a homeowner filed a jurisdictionally valid diversity lawsuit against an electrician in State A federal court to recover damages for breach of contract. The electrician's answer raised three affirmative defenses: (i) that the statute of limitations barred the homeowner's suit in State A; (ii) that the contract was invalid on the grounds of incapacity; and (iii) that the homeowner would not have been entitled to damages under the contract in any event.
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This means that a final judgment in a bench trial requires the trial judge to set forth the factual findings and legal basis for the judgment. The trial judge is not obligated to make findings of fact and conclusions of law pursuant to the disposition of any kind of motion except under FRCP 52(c).
A is correct. A paper that merely states «judgment for the electrician» in a bench trial cannot constitute a final judgment. It may be a final judgment on another motion that does not require specific findings, but the call is asking whether this particular judgment is a final judgment for the electrician. Under FRCP 52, the answer is no because a judge must make specific findings of fact and state his conclusions of law when rendering a judgment following a non-jury trial.
B is incorrect. This is the correct conclusion, but incorrect legal reasoning. The lack of a notation that judgment was entered does not affect the validity of the judgment, especially not in the absence of specific findings and a statement the basis for conclusions.
C is incorrect. It is not true that this judgment would have been properly issued by the court after a bench trial. In fact, this judgment could not have been properly issued in such a scenario, as the court in a non-jury trial must make specific findings and state the basis for conclusions, which was not the case here.
D is incorrect. It is true that this judgment could not be considered final in favor of the electrician following a bench trial, as stated above. However, the type of trial (bench or jury) does affect whether such a judgment is proper. It is the fact that this case was tried without a jury that renders this judgment «not final.» Had this been a jury trial, by contrast, this judgment would have been considered final for the electrician.