Statement Of Decision When Ruling Was By Piecemeal.

After a jury returned a complicated special verdict, the court heard argument on the equitable causes of action. After announcing the decision, the trial court stated that it did not intend its ruling to be final until it had made a decision on the issue of interest. A few months later, the court made a decision on the interest, but asked for briefing on whether or not a receiver should be appointed. Several weeks later, the court made its decisions vis-à-vis a receiver. Eight days after the receiver decision, a party filed a written request for a statement of decision on the equitable issues tried by the court, which request the court denied as untimely. The trial judge later became unavailable and the case was assigned to another judge. The appellate court determined there was no dispute that the party had timely requested a statement of decision pursuant to Code of Civil Procedure section 632, and that the trial judge erred in not issuing one, stating: “We conclude that the only reasonable and workable interpretation of the statute is that the time to request a decision runs from the time the trial court completes the announcement of its decision on all reserved issues.” Because the trial judge was no longer available, the case was remanded for a new trial on the equitable issues. (Wallis v. PHL Associates, Inc. (Cal. App. Third Dist.; October 17, 2013) 220 Cal.App.4th 814.)