Anderson v. City of Bessemer

Supreme Court of the United States · 1985 · Civil Procedure

470 U.S. 564 (1985)

Updated July 29, 2026

Civil ProcedureAppellate ReviewFindings of FactRule 52(a)Title VIIclearly erroneousappellate deferencecredibility determinations

Facts

Bessemer City used a five-member selection committee to hire a Recreation Director, and petitioner was the only woman among eight applicants. The District Court found that petitioner was better qualified than the selected male applicant, that male committee members were biased against hiring a woman, and that petitioner alone was seriously questioned about whether her husband approved of her taking a job involving night work and travel. The court also found the committee's stated reasons for choosing the male applicant pretextual and concluded that petitioner was denied the job because of her sex.

Issue

Did the Court of Appeals misapply Federal Rule of Civil Procedure 52(a) by overturning the District Court's factual findings and ultimate finding of intentional sex discrimination as clearly erroneous? More specifically, may an appellate court reweigh the evidence and reject plausible trial-court findings supported by the record?

Rule

Under Rule 52(a), findings of fact shall not be set aside unless clearly erroneous, and due regard must be given to the trial court's opportunity to judge witness credibility. A finding is clearly erroneous only 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. 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 even if 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.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

After a bench trial in federal court in Denver, a judge found that Sierra Transit Cooperative refused to promote Elena Cruz because of national-origin bias. The evidence was mixed, and the court of appeals concluded that it would have drawn the opposite inference from the same testimony and documents.

Under Rule 52(a), what is the strongest argument that the court of appeals should affirm the trial judge's finding?

Explanation. Rule 52(a) bars de novo reweighing of facts after a bench trial. A factual finding, including discriminatory intent, may be reversed only if clearly erroneous. If the district court's view is plausible on the full record, the court of appeals cannot reverse just because it would have decided differently.