HADLOCK, J.

Petitioner was convicted of two counts of first-degree rape following a jury trial. Petitioner unsuccessfully appealed, then sought post-conviction relief based on allegations that he received inadequate assistance from his trial lawyer. The post-conviction court entered a judgment denying relief. On appeal from that judgment, petitioner first asserts that the court erred when it rejected his inadequate-assistance claim. We reject that argument, which forms the basis for petitioner's first four assignments of error, without discussion. For the reasons that follow, we also reject petitioner's fifth assignment of error, in which he challenges the form of judgment that the post-conviction court entered. Accordingly, we affirm.

The facts pertinent to our analysis are procedural and undisputed. Petitioner's amended petition for post-conviction relief includes a single claim for relief: that petitioner received constitutionally inadequate assistance from his trial lawyer because the lawyer "failed to properly and adequately object" to "vouching" testimony delivered by certain witnesses and also failed to object to certain statements that the prosecutor made during closing argument. A trial was held on the amended petition, at the end of which the post-conviction court orally explained why it was denying the requested relief. That explanation included findings about the adequacy of petitioner's lawyer's performance as well as findings related to petitioner's claim that he was prejudiced by his lawyer's representation.

The court then entered a judgment by completing what appears to be a standard form for use in post-conviction proceedings. That judgment includes the following provisions, among others:

In his fifth assignment of error on appeal, petitioner asserts that the judgment "does not comply with ORS 138.640(1)," as the Supreme Court explained that statute in Datt v. Hill, 347 Or. 672, 227 P.3d 714 (2010). Petitioner contends that the judgment is deficient because it does not indicate "which elements of petitioner's ineffective assistance of counsel [claim] petitioner failed to prove." More specifically, petitioner complains that the judgment does not state whether the post-conviction court denied relief because petitioner failed to prove that his lawyer's performance was constitutionally inadequate or, instead, because petitioner failed to prove that he was prejudiced by any inadequate assistance. Petitioner bases that argument entirely on the fact that the judgment refers, "[i]n handwriting," to findings that the post-conviction court "made on [the] record," and does not spell out those same findings in the judgment document itself. Petitioner does not describe the post-conviction court's oral findings or argue that those findings—had they been detailed in the written judgment— would have been insufficient.

The state responds by asserting that the judgment meets the requirements of ORS 138.640(1), as explained in Datt. In particular, the state observes that the post-conviction court's oral findings address both the inadequate-performance and prejudice prongs of petitioner's post-conviction claim. "Because the post-conviction court's oral ruling clearly explained the basis for rejecting each claim and the judgment incorporated the oral ruling," the state argues, the judgment "satisfied ORS 138.640(1)."

The parties' disagreement thus reduces to a dispute regarding whether ORS 138.640(1) requires that the judgment document itself include a complete explanation of the post-conviction court's ruling, without reference to findings made on the record. To resolve that dispute, we consider both the statute and Datt.

ORS 138.640(1) requires a post-conviction court's judgment to "clearly state the grounds on which the cause was determined, and whether a state or federal question was presented and decided." In Datt, the Supreme Court explained that, to satisfy that clear-statement rule, a post-conviction judgment denying relief must do at least these three things:

347 Or. at 685, 227 P.3d 714. With respect to claims for inadequate assistance of counsel, the judgment does not meet the third Datt requirement unless it identifies which element—constitutionally inadequate performance or prejudice—the petitioner failed to prove:

Id. at 686, 227 P.3d 714; see Soderstrom v. Premo, 274 Or.App. 624, 626, 360 P.3d 1272 (2015) (discussing Datt's requirements and the "clear-statement rule").

Only the third Datt requirement is at issue in this case. Again, the question is whether the post-conviction court can satisfy its obligation to explain "the legal bases for denial of relief" in the judgment by referring to findings that the court made on the record, or whether those findings must be spelled out in the judgment document itself.

In other contexts, it is commonplace for a judgment to include terms that are incorporated into the judgment by reference. See, e.g., Miller and Miller, 269 Or.App. 436, 439, 345 P.3d 472 (2015) (trial court's judgment incorporated the court's oral findings and conclusions regarding each of the statutory factors for determining who should have custody of a minor child); Stoecklin and A.L.C., 265 Or.App. 662, 664-65, 337 P.3d 164 (2014) (supplemental judgment granting parent's petition to change child's last name incorporated the court's oral findings); Pamplin v. Victoria, 138 Or.App. 563, 566, 909 P.2d 1245 (1996) (a judgment dismissing a civil action because of discovery violations incorporated the trial court's oral finding that the plaintiff's attorney acted willfully in ignoring a request for production). Although a trial court's judgment generally prevails over oral pronouncements by the court with which the written judgment document conflicts, State v. Rood, 129 Or.App. 422, 425-26, 879 P.2d 886 (1994), the court's oral findings are not otherwise a nullity, unless a pertinent statute requires the findings to be made in writing.

Nothing in the wording of ORS 138.640(1) imposes more stringent requirements in the post-conviction context. That is, nothing in the statute mandates that the determinations that must be included in the judgment be written out, in potentially lengthy detail, in the judgment document itself, and not simply be incorporated by reference. We conclude that a post-conviction judgment can satisfy the statutory requirement to "clearly state the grounds on which the cause was determined" by incorporating by reference findings that the court made on the record at the post-conviction trial.1

Indeed, Datt itself makes a similar point. In that case, the Supreme Court addressed, among other things, whether the post-conviction judgment met the first of the newly announced Datt requirements: that the judgment "identify the claims for relief that the court considered and make separate rulings on each claim." 347 Or. at 685, 227 P.3d 714. In holding that the judgment fulfilled that requirement, the Datt court did not look only to the judgment document itself. Rather, the court referred to both "the petition and the trial court's statement that `all questions were presented and decided'" to "identify the claims that the court considered and decided: all of the claims that [the] petitioner pleaded." Id. at 685-86, 227 P.3d 714 (emphasis added). Thus, the Datt court itself considered matters of record in the post-conviction proceeding that were not spelled out in the judgment—the nature of the claims in the petition for post-conviction relief—in determining that the judgment adequately "identif[ied] the claims for relief." Id. at 685, 227 P.3d 714.

In short, we conclude that the requirement that a judgment denying post-conviction relief "make the legal bases for denial of relief apparent," id., can be met by oral findings that the post-conviction court makes on the record and incorporates into the judgment by reference. Petitioner's fifth assignment of error is premised on his contrary contention, viz., that oral findings on the record cannot suffice.2 Because we disagree with that proposition, and because we reject petitioner's other four assignments of error without discussion, we affirm the post-conviction court's judgment.

Affirmed.