F.P. v. Monier

F. P. (plaintiff) sued Joseph Monier (defendant) for sexual battery. F. P.’s claims against Monier were tried before the superior court at a bench trial. The trial court issued a tentative decision in which it found that Monier had committed the alleged acts, thereby injuring F. P. The court further indicated that it would award $305,096 in damages, consisting of $44,800 in lost income, $10,296 for past and future medical expenses, and $250,00 for general noneconomic damages. The trial court directed F. P.’s counsel to prepare a judgment. Monier timely requested that the trial court issue a statement of decision setting forth the basis for awarding specific categories of damages. The trial court entered the judgment as prepared by F. P.’s counsel, awarding $305,096 in damages, comprised of $250,000 in general damages and $55,096 in special damages. The court did not issue a statement of decision as requested by Monier. Monier appealed to the California Court of Appeal, arguing that the trial court’s failure to issue a statement of decision rendered its decision reversible per se. The Court of Appeal rejected Monier’s argument, finding instead that the trial court committed error but that such error was subject to harmless-error review. The appellate court further found that the trial court’s error was of no consequence. The California Supreme Court granted review.