Findings of Fact: Just As Important As Conclusions of Law?

Findings of fact refer to the findings of a jury on issues of fact submitted to it and are distinct from conclusions of law. Generally, a jury resolves questions of fact, whereas a judge, or an equivalent resolves questions of law. However, in Rayne, Louisiana, Mary Betty Williams, the plaintiff in a personal injury case, appealed the trial court judge’s determination that she did not carry her burden of proving that the defendant caused the accident at issue.

On December 8, 2009, Ms. Williams and Paula Trahan were involved in an automobile accident in Rayne, Louisiana. Accordingly, Ms. Williams filed suit against Ms. Trahan, asserting that Ms. Trahan caused the accident and was responsible to pay damages to Ms. Williams for pain and suffering, medical expenses, and lost income. At trial, both Ms. Williams and Ms. Trahan offered conflicting testimony that the other was to blame for the accident. Moreover, Ms. Trahan testified that the accident report filed included only portions of the statement she made to Patrolman Joshua Board at the scene of the accident. According to Patrolman Board, he found “a little plastic shard” of debris in the area where the accident occurred, which he believed fell from one of the vehicles involved in the accident. However, Patrolman Board further testified that he never checked either Ms. Williams’ or Ms. Trahan’s vehicle to determine whether the plastic shard had fallen from one of their vehicles or had resulted in damage to either vehicle.

After the accident, Ms. Trahan submitted an amended statement to reflect what she says accurately describes the incident and includes the portions of her statement not included in the initial accident report filed by Patrolman Board. However, at trial, Patrolman Board denied that Ms. Trahan’s amended statement reflected what the she told him at the scene of the accident. Nonetheless, the trial court awarded judgment in favor of Ms. Trahan and dismissed Ms. Williams’s claims, concluding that Ms. Williams had not carried her burden of proof. According to the trial court judge, “the scales are evenly balanced. I don’t feel that the plaintiff has carried her burden, because both versions are plausible, but neither one has more credibility than the other. So this is a case where plaintiff cannot recover, because she could not prove, by a preponderance of the evidence, that the accident was the fault of the defendant in this case.” As a result, Ms. Williams appealed the trial court’s determination and submits that the trial court erred in its conclusion that she did not prove Ms. Trahan caused the accident.

According to the Louisiana Third Circuit Court of Appeals, “[a] trial court’s findings of fact cannot be set aside on appeal unless review of the record shows the trial court’s findings were manifestly erroneous or clearly wrong.” An appellate court must review the entire record and find that no reasonable factual basis exists for the trial court’s findings before it reverses a trial court’s findings of fact. Further, “[t]he court’s review of the record must also establish the fact finder was clearly wrong or manifestly erroneous … [i]f there are conflicts in the testimony, the appellate court should not disturb reasonable evaluations of credibility and reasonable inferences of fact made by the fact finder.” As mentioned above, there were conflicts in the testimonies of Ms. Williams and Ms. Trahan as to how the accident occurred and who was at fault, and as the trial concluded, none of the testimony or the physical evidence resolved these conflicts. Therefore, the Third Circuit of Appeals affirmed the decision below, and after reviewing the record, held that trial court’s findings of fact were not manifestly erroneous or clearly wrong.

On appeal, deference may be given to the findings of fact of lower courts as is often the case with conclusions of law. Thus, the initial trial is extremely important and you need an experienced attorney to present a convincing and credible case to the trial court. At the Berniard Law Firm, our attorneys understand the importance of facts and have the experience and skills to put forth a credible case.