(concurring). I concur with the result reached by the majority, but write separately because I disagree that Carson Fischer Potts & Hyman v Hyman, 220 Mich App 116; 559 NW2d 54 (1996), was wrongly decided. Further, I find the majority’s opinion confusing in that it (1) finds that the differences between Carson and the case before us are “immaterial,” (2) holds that the circuit court has the authority to appoint a special master “as long as the assigned duties do not unduly intrude on the exclusive domain of the court to perform judicial functions,” ante, 584, (a holding essentially indistinguishable from Carson), and yet (3) follows Carson only because compelled to by MCR 7.215(H). Finally, I disagree with the majority’s ultimate determination, ante, 589, that “in the present circumstances the special master’s powers are limited and not a delegation of the judicial function . . . .”
In support of its position that it would affirm but for the precedentially binding effect of Carson, the majority presents two arguments: first, that “the trial court specifically disclaimed any intention to delegate judicial functions to the special master.” Ante, 588. However, that disclaimer, made orally by the trial court at a hearing that occurred after entry of the order appointing the special master, is of no effect. It is well settled that courts speak through their written *591orders, not their oral statements. Boggerty v Wilson, 160 Mich App 514, 530; 408 NW2d 809 (1987).
The majority’s second argument is that the proposed findings of fact and conclusions of law were mere recommendations to the court; that if either side objected, the trial court was responsible to issue its own findings of fact and conclusions of law; and that there was no delegation of judicial authority in view of the oversight and power of review retained by the trial court. However, the order (set forth in its entirety as an appendix to this opinion) makes it clear that, absent objections by the parties, the master’s findings of fact and conclusions of law would become the judgment of the court. Further, the order does not specify that, in the event of objections, the trial court is responsible to issue de novo its own findings and conclusions of law. Rather, the order is silent regarding the court’s role in the event there are objections, leaving the court free to adopt the recommendations notwithstanding objections, order reconsideration by the special master, or take any number of other actions that, advertently or inadvertently, would relieve the court from its obligation to adjudicate the case before it.
While I am extremely sympathetic to the court’s rationale for appointing the special master, as set forth in the introductory paragraph of the order, and while the order in this case does not involve quite as comprehensive a delegation of authority to the special master as the authority delegated to the expert witness in Carson, the order plainly purports to delegate certain functions and powers that are clearly within the purview of the judiciary. In particular, the order appointing the special master delegated the *592duties of making findings of fact and conclusions of law with respect to the validity, propriety, and amount of the claims, requiring the production of evidence, conducting and regulating miscellaneous proceedings, and examining documents and witnesses. In addition, the special master was to provide the court with its recommendations and, if the parties did not object, they would be deemed to have consented to the entry of an order consistent with those recommendations. By delegating these judicial functions to a special master, the trial court exceeded its constitutional and statutory authority. See Carson, supra, 122-124.
The majority seems to be arguing that Carson was Wrongly decided because it prohibits the use of special masters at all. This is evidenced by the majority’s citation of various cases, decided before Carson, wherein circuit courts have appointed special masters to assist them when the circumstances of the case so justified; by the majority’s noting that, while the Michigan Court Rules of 1985 do not expressly authorize or prohibit the appointment of a special master, the majority finds that the circuit court does possess such authority; and by the majority’s holding that, as long as the court’s judicial function has not been abdicated, there is no express or implied prohibition to the appointment. However, the issue in both Carson and in the case before us is not whether the circuit court has authority to appoint such persons, be they called special masters, lieutenants, expert witnesses, amicus curiae, or any other of a number of titles. The issue is whether the circuit court can delegate judicial functions to those individuals. As Carson so clearly and correctly points out, the answer is no.
*593The cases cited by the majority do not dictate a different result. A careful reading of those cases shows that, notwithstanding the appointment of special masters, receivers, or amicus curiae, it was the court that either made the final decision, often following a trial, or was found to have committed error requiring reversal for failure to do so. For example, in Campbell v Evans, 358 Mich 128; 99 NW2d 341 (1959), where the trial court rubber-stamped the custody recommendation of the friend of the court, the Supreme Court reversed, stating:
“While under statutory authority, [circuit courts] are authorized to make use of the friend of the court for detailed home investigation, and to make use of friend of the court referees for preliminary hearings, the circuit judge cannot delegate Ms ultimate responsibility in contested cases for the hearing of evidence and the determination of issues.” [Id., 132 (emphasis added; citation omitted).]
Similarly, while the trial court in O’Connor v Vander Veen, 253 Mich 77, 83; 234 NW 101 (1931), appointed a special master to hear claims against a dissolving copartnership, the court ultimately adjudicated the matter, determining that the appellant intervening creditor was a general and not a preferred creditor of the copartnership and that it could not look to its sureties. Chittenden v Witbeck, 50 Mich 401; 15 NW 526 (1883), involved a bill for a final settlement of partnership affairs. The case was heard by the trial court using the pleadings and proofs, and the court determined that the complainant retained a large portion of partnership assets, used them without consent of the defendants for private gain, and made large profits. The court then referred the case to a special master to take and state an account of the partner*594ship proceedings and ultimately divide the profits consistent with the court’s determination, a situation distinguishable from both Carson and the case before us. In Detroit Trust Co v Mason, 309 Mich 281, 309; 15 NW2d 475 (1944), relied on by the majority, the duties of the friend of the court were clearly circumscribed “not to make any decision for the court but to obtain other plans and make recommendations, the court reserving to itself the exclusive right to make the final determination”; while acknowledging authority for the appointment of a friend of the court, the Court based its holding on the fact that no objections were made. Id., 310. In Rockwell v Crestwood School Dist Bd of Ed, 393 Mich 616, 644-645; 227 NW2d 736 (1975), cited by the majority, the Court was unpersuaded by the union’s argument that arbitrators were analogous to special masters, and, in dicta, noted the differences as follows:
A special master, receiver or monitor exercises the powers conferred upon him subject to the judge’s power to substitute his own independent judgment at any time for the judgment of the special master, receiver or monitor unimpeded by the limitations generally pertaining when a court sits in judicial review of an arbitrator’s decision.
Rather than contradicting Carson, this dicta supports, albeit indirectly, Carson’s conclusion that judicial authority rests with the court, not with a special master. In Harper Creek School Dist v LeRoy Twp Supervisor, 146 Mich App 515; 382 NW2d 172 (1985), the parties stipulated that the cases be consolidated, that the judgment be stayed pending appeal, and that the issue of reasonable costs of summer tax collection by the townships would be determined by a special master. However, it was the court that made the *595four dispositive rulings regarding the constitutionality and the requirements of 1982 PA 333. In O’Dess v Grand Trunk W R Co, 218 Mich App 694; 555 NW2d 261 (1996), the parties stipulated that a special master be appointed for the purpose of determining whether the plaintiffs’ predecessors’ deeds conveyed to the defendant’s predecessor a fee interest and the nature of that interest. The master made findings of fact only, i.e., that the deeds conveyed a fee simple interest in the property, but the trial court, having adopted those findings, made its ruling of law that, on the basis of a Supreme Court case, the land was not subject to certain statutory deed-back provisions. In short, none of these cases supports the majority opinion that Carson was wrongly decided.
Importantly, the majority does not distinguish between the significant authority given only to the Supreme Court as opposed to that given to the Court of Appeals and the circuit courts. This is evidenced by the majority’s citation of the reapportionment and the Durant cases, Durant v State Bd of Ed, 424 Mich 364; 381 NW2d 662 (1985), and Durant v Michigan, 456 Mich 175; 566 NW2d 272 (1997). Const 1963, art 6, § 5 provides that the “supreme court shall by general rules establish, modify, amend and simplify the practice and procedure in all courts of this state.” (Emphasis added.) Pursuant to this authority, chapter 9 of the Michigan Court Rules (Professional Disciplinary Proceedings) provides that the Attorney Grievance Commission can “direct that the hearing be held before a master to be appointed by the Supreme Court.” MCR 9.210. See Grievance Administrator v August, 438 Mich 296, 304; 475 NW2d 256 (1991). Similarly, Const 1963, art 6, § 23 provides that the *596“supreme court may authorize persons who have been elected and served as judges to perform judicial duties . . . (Emphasis added.) The apportionment cases and the Durant cases, cited by the majority, are distinguishable. The former generally utilize persons appointed by the Supreme Court (see, e.g., In re Apportionment of the State Legislature — 1992, 439 Mich 251; 483 NW2d 52 [1992]), and the latter deal with the Headlee Amendment, Const 1963, art 9, §§ 25-34, which provides in § 32 that state taxpayers have standing to bring suit in the Court of Appeals. In sum, the authority given to the Supreme Court is both qualitatively and quantitatively different from that given to the circuit court. While the circuit court may appoint various lieutenants, it may not delegate judicial functions or authority to those lieutenants, and Carson, supra, correctly so held.
Finally, I would find no merit in appellee’s argument that this Court need not review this issue because it may be rendered moot by the adoption of proposed MCR 2.317. As a general rule, this Court does not decide moot issues. B P 7 v Bureau of State Lottery, 231 Mich App 356, 359; 586 NW2d 117 (1998).
An issue is deemed moot when an event occurs that renders it impossible for a reviewing court to grant relief. Id. At the time the order appointing the special master was entered, MCR 2.317 had not been adopted. While proposed MCR 2.317 would authorize the appointment of “discovery masters” to facilitate discovery, there is no indication that the rule is to be applied retroactively. Moreover, even if proposed MCR 2.317 is ultimately adopted and were applied retroactively, the trial court’s order appointing a special master in the case before us would still appear to be *597overbroad. See proposed MCR 2.317(B). Nor is there merit to appellee’s claim that the trial court’s appointment is valid under the authority granted in MCR 1.105. If MCR 1.105 is read in such a broad manner, it would grant a court the power to enter any order to quickly dispose of a case. Such a broad reading of the rule is contradicted by the Michigan Constitution, which clearly limits a trial court’s authority.
I join the majority’s opinion to reverse.
APPENDIX
ORDER APPOINTING SPECIAL MASTER
This matter comes before the Court upon the Assignment for the Benefit of Creditors of Beckwith Evans, Inc. (“Beck-with Evans”) and upon the Complaint (the “Complaint”) of the Oakland Prosecutor for determination of claims of violation of the Michigan Consumer Protection Act. Recognizing the urgency of the claims and the fact that they number almost 300, the Court must balance the Prosecutor’s request for an immediate resolution with the demands of the Court’s extensive civil and criminal docket. The Court has the duty not only to these parties but also to those in the other cases that come before it on a daily basis and it cannot set those aside to resolve this matter. To comply with MCR 1.105 and to meet its duties to all of the citizens of Oakland County, the Court has determined that the best interests of the parties will best be served by the appointment of a special master to assist the Court.
It is therefore ordered as follows:
1. Geoffrey L. Silverman of the law firm Shefferly & Silverman is hereby appointed as Special Master (“Special Master”) to assist the Court as set forth herein and as may be directed by the Court from time to time. The Special Master may delegate certain duties to and receive the assistance of other attorneys and staff members of the firm of Shefferly & Silverman as he may deem necessary or advisa*598ble in performance of his duties and exercise of his powers hereunder.
2. The Special Master shall provide the Court with written recommendations of findings of fact and of conclusions of law with respect to the following:
A. The validity and amount of claims alleged under the Michigan Consumer Protection Act (MCLA 445.901 et seq)
[sic] alleging fraud and misrepresentation by and on behalf of Beckwith Evans; and
B. The priority of all claims against the assets of Beck-with Evans, including, but not limited to, those of (i) customers for deposit, (ii) the Assignee for the Benefit of Creditors and those providing services to him pursuant to such assignment, and (iii) others asserting lien claims.
3. The parties hereto shall have fourteen (14) days from and after service of the Special Master’s recommendations in order to file and serve any written objections thereto. Absent the timely filing and service of such objections, a party shall be deemed to have consented to the entry of an order adopting and confirming such recommendations.
4. The Special Master shall consult with and advise the Court as the Court may request from time to time.
5. The Special Master may conduct fact-finding inquiries by meeting with the parties by requests for written submissions and/or the taking of oral evidence. The Special Master shall not be required to make rulings as to the admissibility of any evidence or other submissions, but shall note and preserve any and all evidentiary objections.
6. The Special Master may establish schedule(s) for completion of his duties and may direct the parties to meet with him and/or to submit written materials on or by dates certain for the purpose of establishing the procedure to be followed by the Special Master and the parties, the sharing and/or presentation of information and/or evidence, and/or the presentation of oral argument. The Special Master may permit, but is not required to permit, oral argument or oral presentation.
7. The Oakland County Prosecutor is hereby directed to provide the Special Master, the Assignee for the Benefit of Creditors and counsel for Beckwith Evans, within fourteen *599(14) days of the date hereof, with a specific statement of the alleged misrepresentation and/or fraud as to each consumer for the benefit of whom the Prosecutor has filed the Complaint. Such statement shall indicate the nature of the alleged misrepresentation and/or fraud and the facts giving rise thereto, including a description of the person (s) (with names, if known) making such statements [sic] the dates upon which such statements or acts were made or taken, and the manner in which the respective consumer relied thereon.
8. The Special Master shall be compensated for his services and the services of other employees of the firm of Shefferly & Silverman based on the time spent on such tasks and calculated at the regular hourly billing rates of such attorneys and other personnel, in effect as of July 1, 1996. The Special Master shall be reimbursed the out-of-pocket expenses reasonably incurred by him and by Shefferly & Silverman in performance of these duties. Such fees and expenses shall be borne equally by the Oakland County Prosecutor and by the Assignee for Benefit of Creditors and shall be due and payable from time to time, immediately upon receipt of detailed invoice(s). As to the Assignee for the Benefit of Creditors, the obligations to pay fees and expenses of the Special Master hereunder shall have priority over any and all other fees, expenses and distributions to be made pursuant to such Assignment.