California
Appeals

Standard of Review-Implied findings substantial evidence -School Employees v Tustin School Dist G037118

II.

The School District’s Laches, Estoppel, and Unclean Hands Defenses Have No Merit.

The School District asserted affirmative defenses of laches, estoppel, and unclean hands, any one of which, it argues, supported denial of the Petition.  The trial court made no findings on those affirmative defenses.  The CSEA did not request a statement of decision, object to the court’s order, or otherwise bring those omissions to the trial court’s attention.  Thus, under the doctrine of implied findings, we infer the trial court made any and all findings necessary to support the judgment.  (In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133-1134; SFPP v. Burlington Northern & Santa Fe Ry. Co. (2004) 121 Cal.App.4th 452, 462.)  We review the implied findings under the substantial evidence standard.  (In re Marriage of Arceneaux, supra, 51 Cal.3d at pp. 1133-1134; SFPP v. Burlington Northern & Santa Fe Ry. Co., supra, 121 Cal.App.4th at p. 462.)  Nonetheless, we conclude the School District failed to submit evidence supporting its affirmative defenses, or they fail as a matter of law.

 

Cal. School Employees v.Tustin School DistG037118