## Facts

- Husband and wife married in 1978 and separated in 1984.
- After a dissolution judgment, the superior court held a 1988 trial on reserved issues, including valuation of husband’s medical practice, characterization/valuation of a 1979 Mercedes Benz, and awards of attorney’s and accountant’s fees.
- Near the close of evidence, husband’s counsel made an oral request under Code of Civil Procedure § 632 for a statement of decision explaining the method used to value the medical practice.
- The trial judge indicated counsel could file a written request; none was filed.
- The court entered a further judgment adopting wife’s valuation of the medical practice, finding the Mercedes to be community property valued at $13,000 and assigned to husband, and awarding wife $20,000 in attorney’s fees plus accountant’s fees.
- Husband appealed, arguing entitlement to a statement of decision and challenging the Mercedes and fee awards.

## Issues

1. Whether a request for a statement of decision under Code of Civil Procedure § 632 may be made orally if timely and specific.
2. Whether the trial court erred by failing to issue a statement of decision addressing the method of valuing husband’s medical practice after a proper request.
3. Whether substantial evidence and proper discretion supported the trial court’s rulings on (a) the Mercedes’s community characterization and valuation and (b) attorney’s and accountant’s fee awards.

## Decision

- The Court of Appeal held an oral request for a statement of decision under § 632 is permissible if timely and sufficiently specific.
- The trial court erred by failing to provide a statement of decision on the valuation method for the medical practice after husband’s oral request.
- The judgment was reversed and remanded solely on the medical-practice valuation, with directions to issue a statement of decision and reconsider that issue as appropriate.
- The judgment was affirmed as to the Mercedes characterization/valuation and as to attorney’s and accountant’s fees.

## Legal Principles

- Code of Civil Procedure § 632 requires a statement of decision on principal controverted issues when timely requested; the statute’s timing requirement does not impose a writing requirement for the request.
- Failure to issue a statement of decision after a proper § 632 request is reversible error where the omission prevents meaningful appellate review of a complex factual determination, such as valuation of a professional practice.
- On appeal, property characterization and valuation findings are reviewed for substantial evidence, with deference to the trial court’s credibility determinations and weighing of conflicting evidence.
- In dissolution proceedings, the trial court has broad discretion to award attorney’s fees and related expert fees; it may determine reasonableness based on its observation of the proceedings without requiring independent testimony on value.

## Conclusion

The court ruled that a timely, specific oral request triggers the duty to issue a statement of decision under § 632, reversed and remanded for a statement and reconsideration of the medical-practice valuation, and otherwise affirmed the trial court’s community-property and fee determinations.


In re Marriage of Ananeh-Firempong, 219 Cal. App. 3d 272, 268 Cal. Rptr. 83 (Ct. App. 1990)