A.G. v. C.S.Annotate this Case
Mother C.S. appealed an order awarding sole custody of her children to Father A.G. Mother argued the trial court erred by: (1) not basing its order on the children’s best interests; (2) committing prejudicial evidentiary rulings; (3) denying Mother’s request during trial for a continuance to obtain counsel; and (4) committing separate errors that constituted cumulative error. The Court of Appeal disagreed with Mother’s contentions and affirm the order. As part of its decision, the Court also concluded the "doctrine of implied findings" applied in this case where the parties did not request a statement of decision, the court did not prepare one, and the settled statement used by the parties did not contain an express statement by the trial court that it complied with the procedures required for adopting a statement of decision and that the settled statement serves as the court’s statement of decision.