California, United States of America
The following excerpt is from Moss v. Superior Court (Ortiz), 17 Cal.4th 396, 71 Cal.Rptr.2d 215 (Cal. 1998):
3 We deem the minute orders reflecting these two rulings together to be the "judgment of contempt" in this matter. Code of Civil Procedure section 1218 provides that the finding of contempt is to be incorporated into the judgment of contempt (Reifler v. Superior Court (1974) 39 Cal.App.3d 479, 484, 114 Cal.Rptr. 356), however. We therefore disapprove the practice reflected here. Moreover, while an indirect contempt judgment need not recite the court's factual findings as a jurisdictional prerequisite, those findings should be specifically recited orally or in the judgment to assist a reviewing court in determining if the evidence is sufficient to support the judgment of contempt.
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