Short answer. Not entirely — only as to the facts. Section 12 provides that when parties stipulate a commissioner's findings of fact shall be final, only questions of law are thereafter considered, meaning the factual findings become unchallengeable but legal issues arising from those facts can still be contested.
What the law says
When the parties stipulate that a commissioner's findings of fact shall be final, only questions of law shall thereafter be considered.
Rule 32, Section 12 — Stipulations as to findings. Read the full provision →
What the stipulation locks in
An agreement that the commissioner's factual findings will be final removes those specific facts from further dispute — the parties can no longer relitigate what actually happened once the commissioner has made the finding. In practice, this usually covers the kind of detailed factual work commissioners are appointed to handle in the first place, such as the results of an accounting, the value or extent of property in a partition, or computations arising from a long or complicated account under Section 2 of the Rule.
What remains open
The stipulation does not extend to legal conclusions; only questions of law are considered thereafter, so a party can still argue that the commissioner, or the court adopting the commissioner's report, misapplied the law to the now-fixed facts. That means a party unhappy with the outcome is not left without recourse — they simply have to frame their challenge as a legal error rather than as a factual dispute the commissioner supposedly got wrong.
Why parties might choose this
Stipulating finality on facts can streamline a case with complex or technical factual issues, of the kind commissioners often handle in long-account or accounting disputes under Section 2, by letting the parties focus the remaining dispute purely on legal questions once the facts are settled. It can also shorten the overall proceeding, since the court and the parties no longer need to revisit the underlying factual record each time a legal issue comes up on review.
How this differs from an unstipulated report
Without such a stipulation, a party can typically contest both the commissioner's factual findings and any legal conclusions when the report comes before the court for action. Agreeing in advance to treat the factual findings as final trades away that broader avenue of challenge in exchange for a narrower, faster review focused only on law — a tradeoff parties may find worthwhile when they trust the commissioner's fact-finding but still want the court, not the commissioner, to have the last word on legal questions. Because the stipulation is a matter of party agreement rather than something the Rule imposes automatically, it does not bind parties who never signed on to it, and a party who later regrets the stipulation cannot unilaterally withdraw from it simply because the commissioner's findings turned out unfavorably.