Legal Definitions - manifest-error-or-clearly-wrong rule

The manifest-error-or-clearly-wrong rule is a legal principle that limits the power of an appeals court to overturn a trial court's factual findings.

In many legal systems, a trial court (where a case is first heard, with a judge or jury determining the facts) is considered to be in the best position to assess evidence and witness credibility. Therefore, an appellate court (which reviews decisions made by trial courts) generally gives significant deference to the trial court's conclusions about what actually happened.

Under this rule, an appellate court cannot simply disagree with a trial court's finding of fact and overturn it. Instead, the appeals court can only set aside a trial court's factual finding if, after reviewing the entire record of the trial proceedings, it becomes clear that the finding has no reasonable basis in the evidence presented. In other words, the trial court's factual conclusion must be so obviously incorrect or unsupported by any credible evidence that it constitutes a "manifest error" or is "clearly wrong." This is a very high standard, meaning appeals courts rarely overturn factual findings, focusing more on whether the law was applied correctly.

Here are some examples to illustrate this rule:

• Example 1: Witness Credibility in a Fraud Case

  Imagine a trial where a judge hears conflicting testimony from two witnesses regarding whether a fraudulent statement was made. The judge, observing the witnesses' demeanor and considering all evidence, decides to believe Witness A over Witness B, concluding that fraud did occur. The losing party appeals, arguing the judge should have believed Witness B instead.

  How it illustrates the rule: An appellate court reviewing this case would apply the manifest-error-or-clearly-wrong rule. They would not overturn the trial judge's finding of fraud simply because they might have personally found Witness B more credible. Unless the trial record showed absolutely no reasonable basis for the judge to believe Witness A (e.g., Witness A's testimony was physically impossible or contradicted by irrefutable documents), the appellate court would uphold the trial judge's factual finding that fraud occurred. The judge's assessment of credibility is a factual finding given great deference.

• Example 2: Damages Calculation in a Breach of Contract Case

  In a lawsuit concerning a breached construction contract, the trial judge reviews invoices, expert reports, and testimony about project delays and additional costs. Based on this evidence, the judge calculates and awards a specific amount of damages to the plaintiff. The defendant appeals, arguing the damages amount is too high and not supported by the evidence.

  How it illustrates the rule: The appellate court would examine the trial record to see if there was a reasonable basis for the judge's calculation of damages. If the judge's figure, while perhaps debatable, was derived from credible evidence presented at trial (like expert testimony on costs or documented losses), the appellate court would likely affirm the award. They would only overturn it if the damages calculation was so wildly out of line with all the evidence that it had "no reasonable basis" and was "clearly wrong," indicating a manifest error in the judge's factual assessment of the financial losses.

• Example 3: Property Line Dispute

  Two neighbors go to trial over the exact location of their shared property boundary. The trial judge hears from multiple surveyors, reviews old deeds, and considers aerial photographs. After weighing all this information, the judge makes a specific factual finding about where the property line lies. One neighbor appeals, claiming the judge's determination of the boundary is incorrect.

  How it illustrates the rule: The appellate court would review all the evidence presented at trial, including the conflicting surveyor reports and historical documents. If the trial judge's conclusion about the boundary line is supported by *any reasonable interpretation* of the evidence in the record, even if other evidence might have suggested a slightly different line, the appellate court would uphold the trial judge's factual finding under the manifest-error-or-clearly-wrong rule. They would only overturn it if the judge's finding was completely unsupported by any credible evidence, making it a manifest error.