Anderson v. City of Bessemer City
In Anderson v. City of Bessemer City, 470 U.S. 564, 105 S. Ct. 1504, 84 L. Ed. 2d 518 (1985), the Supreme Court observed that various Courts of Appeals have on occasion asserted the theory that findings not based on credibility determinations may be reviewed de novo. Id. at 574, 105 S. Ct. at 1511-12.
The Supreme Court noted, however, that the "rationale for deference to the original finder of fact is not limited to the superiority of the trial judge's position to make determinations of credibility." Id. at 574, 105 S. Ct. at 1512.
The Supreme Court reasoned that a trial court's experience with fact finding also brings experience and expertise. Duplication of the trial judge's efforts on appeal "would very likely contribute only negligibly to the accuracy of fact determination at a huge cost in diversion of judicial resources." Id. at 575, 105 S. Ct. at 1512.
Moreover requiring the parties to convince three rather than one judge that their account of the facts is the correct one requires too much energy and resources. Id. The Supreme Court further recognized that Rule 52(a), states straightforwardly that findings of fact cannot be set aside unless clearly erroneous, and the Rule does not exclude categories of factual findings from the obligation to accept a trial court's findings unless clearly erroneous. Id. at 573-74, 105 S. Ct. at 1511-12.