.  The implied findings doctrine applies when the parties do not request a statement of decision even if the record on appeal is a settled statement.  The use of a settled statement in lieu of a reporter’s transcript does not negate the implied findings doctrine, if the parties have waived a statement of decision, since the settled statement is a record of what was said, not a record of the trial court’s reasoning.

California Court of Appeal, Third District (Nicholson, Acting P.J.); April 27, 2016; 2016 WL 1715191