Lansford-Coaldale Joint Water Authority v. Tonolli Corp.
United States Court of Appeals for the Third Circuit
4 F.3d 1209 (3d Cir. 1993)
The Water Authority (plaintiff) sued Tonolli (defendant) claiming hazardous substances from its smelting site contaminated the Authority's wells; after trial, the judge orally ruled for Tonolli within hours of closing arguments and directed Tonolli's counsel to draft the formal findings, conclusions, and judgment, largely adopting them verbatim without waiting for a transcript or writing an independent opinion. The Authority appealed, arguing the findings didn't satisfy Rule 52(a) given their rapid, party-drafted, pre-trial-request origin.
Whether findings and conclusions prepared by a party and adopted by the judge adequately serve the purposes of Federal Rule of Civil Procedure 52(a).