Anderson v. Bessemer City

470 U.S. 564 (1985)

What's Going On?

Petitioner seeks review of an appellate court decision reversing the district court's finding that Respondent discriminated against her based on her gender.

Who's Who?

Petitioner     :

Anderson – applicant for the position of Recreation Director of Respondent Bessemer City (original plaintiff).

Respondent :

Bessemer City – municipal government, rejected Anderson for employment as its Recreation Director (original defendant).

Facts:

Petitioner Anderson was one of nine applicants for the position of Recreation Director of Respondent Bessemer City. Petitioner, the only woman to apply, was not hired. Petitioner filed a suit for discrimination against Respondent under Title VII of the Civil Rights Act of 1964. The district court found that Petitioner had been denied employment because of her sex, and made the subsidiary factual findings (1) that Petitioner was better qualified than the successful applicant; (2) that male members of Respondent's selection committee were biased against Petitioner because of her sex; (3) that Petitioner was asked questions that other applicants were spared; and (4) that the reasons offered by the male committee members for choosing the successful applicant were pretextual. The appellate court reversed, holding that all but the fourth factual finding of the district court were clearly erroneous. The Supreme Court granted certiorari.

Issue:

May an appellate court conduct what amounts to a de novo review in reviewing the factual findings of the trial court?

Decision:

No. A finding of intentional discrimination is a finding of fact which is governed by FRCP 52(a). Rule 52(a) provides that findings of fact may be reversed only if they are clearly erroneous. A finding is clearly erroneous when, although there is evidence to support it, the reviewing court is left with the definite and firm conviction that a mistake has been committed, after considering the evidence in its entirety. When there are two permissible views of the evidence, however, the factfinder's choice between them cannot be clearly erroneous. In this case, the appellate court improperly conducted a de novo weighing of the evidence in the record. The district court reached its conclusion that Petitioner was better qualified than the successful applicant based on essentially undisputed evidence regarding the respective backgrounds of both candidates. The appellate court reviewed the same evidence, but concluded that the successful applicant was better qualified. The task of the appellate courts, however, is to question whether the district court's findings were clearly erroneous. In light of the record, it cannot be said that the district court's conclusions were clearly erroneous. Reversed.

Basic Rule:

Appellate courts must apply the clearly erroneous standard of review in reviewing findings of fact.

Terms:

Clearly erroneous :

Standard of review under which a reviewing court will uphold a judgment unless it is certain that an error was made in reaching the judgment.

De novo review :

Standard of review under which the court reviews the facts of the case and makes determinations without giving deference to the judgment of the lower court.

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