Also known as: manifestly wrong · clearly erroneous · clearly erroneous standard · manifest error
Written by attorneys · grounded in primary & secondary sources — see below
A deferential standard of appellate review under which a trial court's factual findings receive strong deference and are upheld unless the record shows they lack substantial evidentiary support or rest on a plain mistake.
Monica Morgan sued Midwest Airlines after a bench trial on contract damages. The district court credited the airline's operations manager over Morgan's expert and found no breach. On appeal Morgan argued the findings were clearly erroneous because the expert's sampling data was more detailed. The appellate court affirmed because the trial judge had observed the witnesses and the record contained competing evidence that supported crediting the manager.
Maurice Marshall challenged a zoning denial that blocked low-income housing. The trial court found no discriminatory intent after weighing testimony from village officials. On appeal Marshall claimed the findings were manifestly wrong because statistical patterns showed disparate impact. The reviewing court upheld the findings because the trial judge had the best opportunity to assess credibility and the record supported a nondiscriminatory motive.
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Miguel Mendoza filed a federal suit seeking custody modification after a state divorce decree. The district court found the case fell within the domestic relations exception and dismissed. On appeal Mendoza argued the factual premise that the dispute involved core family issues was clearly erroneous. The appellate court affirmed because the trial court's characterization of the claims rested on a permissible reading of the pleadings and evidence.
Miranda Morales sued after hospital staff tested her urine for drugs under a city policy. The trial court found the testing was not a Fourth Amendment search because patients consented. On appeal Morales contended the consent finding was manifestly wrong given the coercive circumstances. The reviewing court upheld the finding because the trial judge had credited the hospital's testimony and the record contained evidence of voluntary participation.
Matrix Technologies sponsored a student newspaper that the principal censored. The trial court found the principal's actions reasonable under school-speech standards after hearing testimony from administrators and students. On appeal the sponsor argued the reasonableness finding was clearly erroneous. The appellate court affirmed because the trial judge had the opportunity to judge credibility and the record supported the principal's pedagogical concerns.
Ming Ma challenged a state military institute's male-only admissions policy. The trial court found the policy served important governmental objectives after reviewing historical and expert evidence. On appeal Ma argued the findings were manifestly wrong because less restrictive alternatives existed. The reviewing court upheld the findings because the trial judge had weighed the evidence firsthand and the record supported the conclusion that the policy was substantially related to the objectives.
The appellant must demonstrate that the findings lack substantial support in the record or rest on a plain mistake of fact. Mere disagreement with how the trial court weighed the evidence is insufficient. The reviewing court must give due regard to the trial judge's opportunity to assess witness credibility.
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No. A party may later question the sufficiency of the evidence supporting the findings whether or not the party requested findings, objected to them, moved to amend them, or moved for partial findings.
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A district judge may modify or set aside any part of the magistrate's order that is clearly erroneous or contrary to law. The same deferential review applies to factual determinations made by the magistrate.
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The findings may be insufficient to permit meaningful appellate review under the clearly erroneous standard. The appellate court can remand for entry of proper findings rather than attempting to review an inadequate record.
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…have a negative effect on property values and the safety of the neighborhood. The Court of Appeals rejected this finding as clearly erroneous. City of Cleburne, Texas v. Cleburne Living Center, Inc. <!-- acedexams opinion md v1 -- Case information - Court: Supreme Court of the United States - Docket No.:…