Lansford-Coaldale Joint Water Authority v. Tonolli Corp.

Lansford-Coaldale Joint Water Authority (the authority) (plaintiff) provided public water. Tonolli Corp. (defendant) owned a smelting site near the authority’s groundwater production and supply wells. The authority sued Tonolli, claiming that hazardous substances from Tonolli’s facility had contaminated its wells. The court held a bench trial, meaning that the case was tried before just the judge, without a jury, and the judge was the finder of fact. Prior to the trial, both parties submitted proposed findings of fact and conclusions of law to the district court. The trial took nine days, spread out over a three-month period. Within hours of the trial’s end, the district court made oral findings of fact that reflected Tonolli’s pretrial proposed findings of fact almost verbatim. The district court did not issue a written opinion explaining its decisions. The authority appealed to the United States Court of Appeals for the Third Circuit. The authority argued that the trial court’s factual findings did not satisfy the spirit of Federal Rule of Civil Procedure (FRCP) 52(a). The authority complained that the district court made its findings within a few hours after the trial ended, instead of waiting for a transcript and taking the time to write an opinion. The authority also objected that the court had not requested new, updated proposed factual findings from both parties after the trial. Additionally, the authority argued that the court’s findings were not entitled to deference because most of the findings were adopted verbatim from Tonolli’s proposed findings of fact.