Anderson v. City of Bessemer City

Brief Fact Summary.

Petitioner sued Respondent for sex discrimination.

Synopsis of Rule of Law.

Under Rule 52, a trial court’s findings of fact may only be set aside by an appellate court if the finding was clearly erroneous.

Facts.

Anderson (Petitioner) sued Bessemer City (Respondent) under Title VII of the Civil Rights Act of 1964 for discrimination on the basis of sex after declining to hire her for a management position.

Issue.

Was the trial court’s factual finding that Petitioner was discriminated against on the basis of sex clearly erroneous?

Held.

No, the trial court’s conclusion was not clearly erroneous. The Appeals Court’s decision is reversed.

Discussion.

The Court determined that none of the trial court’s findings of fact could be considered clearly erroneous. Even when the evidence can be viewed in multiple ways, the trial court’s determination regarding them cannot be clearly erroneous. Here, the finding that Petitioner was the most qualified candidate was based on undisputed evidence and the trial court’s determination based on this evidence was entitled to deference. The finding that Petitioner had been asked additional questions was based on oral testimony and the  trial court’s live interpretation of that testimony was entitled to deference. The finding that male committee members were biased against hiring a woman was supported by the other two findings and entitled to deference.