Law School Case Brief
Anderson v. Bessemer City - 470 U.S. 564, 105 S. Ct. 1504 (1985)
If the district court's account of the evidence is plausible in light of the record viewed in its entirety, the court of appeals may not reverse it even though convinced that had it been sitting as the trier of fact, it would have weighed the evidence differently. Where there are two permissible views of the evidence, the factfinder's choice between them cannot be clearly erroneous. This is so even when the district court's findings do not rest on credibility determinations, but are based instead on physical or documentary evidence or inferences from other facts.
Petitioner Phyllis A. Anderson, a 39-year-old female schoolteacher with college degrees in social studies and education, applied and was rejected for a job managing a city's recreational facilities and programs. A 24-year-old male who had recently graduated from college and had a degree in physical education was chosen for the position by a selection committee which consisted of four men and one woman. Only the woman on the committee voted to hire the female applicant. After obtaining a right-to-sue letter from the Equal Employment Opportunity Commission, the woman brought suit against respondent Bessemer City, North Carolina, alleging sex discrimination under Title VII of Civil Rights Act of 1964, 42 U.S.C.S. §§ 2000e et seq. Following a trial, the District Court determined that Anderson had been denied the position on account of her sex. The court issued a preliminary memorandum setting forth its essential findings and directed Anderson's counsel to submit a more detailed set of findings consistent with them. The District Court's final decision included findings thatAnderson was the most qualified candidate, that she alone had been asked questions about her spouse's reaction to her taking the job, and that the male committee members were biased against hiring women. The United States Court of Appeals for the Fourth Circuit reversed, holding that the District Court's findings were clearly erroneous and that the lower court had erred in finding that the applicant had been discriminated against on account of her sex. Anderson sought a writ of certiorari.
Did the lower appellate court err in reversing the finding of discrimination of the federal district court?
The United States Supreme Court held that the "clearly erroneous" standard did not entitle a reviewing court to reverse a finding of trier of fact simply because it was convinced that it would have decided case differently. The Court further held that the lower appellate court improperly conducted what amounted to de novo weighing of evidence in the record. When the record was examined in light of the appropriate standard, it contained nothing that mandated the finding that the district court's conclusion was clearly erroneous.
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