Anderson v. Bessemer City

Supreme Court of the United States
(1985)

ELI5:

Rule of Law:

Under Federal Rule of Civil Procedure 52(a), an appellate court may only overturn a trial court's findings of fact if they are 'clearly erroneous.' A finding of fact is not clearly erroneous if the trial court's account of the evidence is plausible in light of the entire record, even if the appellate court would have weighed the evidence differently.

Facts:

In 1975, Bessemer City, North Carolina, formed a five-member committee (four men, one woman) to hire a new Recreation Director.
Phyllis Anderson, a 39-year-old schoolteacher with varied experience, was the only female applicant among eight candidates.
During her interview, Anderson was the only applicant asked serious questions about her family life, including whether her husband approved of her applying for a job that required night work.
One male committee member solicited applications only from men.
Another male committee member testified that he believed it would have been 'real hard' for a woman to handle the job.
The committee, on a 4-1 vote with the four male members in favor, offered the position to Donald Kincaid, a 24-year-old male with a degree in physical education but less varied experience than Anderson.
The sole female committee member voted for Anderson.

Procedural Posture:

Phyllis Anderson filed sex discrimination charges with the Equal Employment Opportunity Commission (EEOC).
After conciliation efforts failed, the EEOC issued Anderson a right-to-sue letter.
Anderson sued Bessemer City in the U.S. District Court for the Western District of North Carolina for violating Title VII.
Following a bench trial, the District Court found that Bessemer City had intentionally discriminated against Anderson and awarded her backpay and attorney's fees.
Bessemer City, as appellant, appealed the judgment to the U.S. Court of Appeals for the Fourth Circuit.
The Court of Appeals reversed, holding that the District Court's key factual findings supporting discrimination were clearly erroneous.
Anderson, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.

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Issue:

Did the Court of Appeals misapply the 'clearly erroneous' standard of review under Federal Rule of Civil Procedure 52(a) when it reversed the District Court's factual finding of intentional sex discrimination?

Opinions:

Majority - Justice White

Yes. The Court of Appeals misapplied the 'clearly erroneous' standard by impermissibly re-weighing the evidence. A reviewing court cannot reverse a trial court's finding of fact simply because it is convinced it would have decided the case differently. The District Court's conclusion that Anderson was more qualified was a plausible view of the evidence. Furthermore, the Court of Appeals failed to give proper deference to the trial court's credibility determinations, particularly its finding that discriminatory questions were posed only to Anderson. When a trial judge's finding is based on a decision to credit the testimony of one of two or more witnesses telling coherent and plausible stories, that finding can virtually never be clear error. Because the District Court's subsidiary findings on qualifications, questioning, and bias were not clearly erroneous, its ultimate finding of intentional discrimination must stand.

Concurring - Justice Powell

Yes. Justice Powell concurred in the judgment, agreeing that the Court of Appeals misapplied Rule 52(a). He wrote separately to caution that the majority's opinion should not be read to discourage appellate courts from conducting a thorough and comprehensive review of the entire record. He noted that while one could easily agree with the Court of Appeals' conclusion based on the 'fragmentary' evidence, the factual issue could have been fairly decided for either party, which is precisely why the District Court's decision was not clearly erroneous.

Concurring - Justice Blackmun

Yes. Justice Blackmun concurred only in the judgment, not the full opinion. He agreed with the result but objected to the majority's 'broad dictum' that the clearly erroneous standard applies with the same force to findings based on documentary evidence as it does to those based on witness credibility. He argued that the Court should not decide that broader question in a case like this, which rested heavily on testimonial evidence, and should instead wait for a case where the issue is directly presented and argued.

Analysis:

This decision significantly reinforces the deference appellate courts must give to a trial court's findings of fact under the 'clearly erroneous' standard. It clarifies that this standard is not a license for appellate courts to conduct a de novo review or act as a second trier of fact. By extending this strong deference to findings of 'ultimate' facts, such as discriminatory intent, the Court makes it much more difficult to successfully appeal civil rights and employment discrimination cases on factual grounds, thereby solidifying the trial court's central role as the primary fact-finder.

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