A plaintiff brought a negligence action against a defendant in federal court after a car accident. During trial, the jury found that the defendant was not negligent. The plaintiff appeals, arguing that the jury’s factual findings were against the weight of the evidence presented. On appeal, what is the most appropriate standard of review that the appellate court should apply to the jury’s factual findings?
The appellate court should review the jury’s factual findings with no deference to the trial court’s proceedings.
The appellate court should independently reevaluate the evidence and make its own findings of fact.
The appellate court should review the jury’s factual findings under a 'manifest error' or 'clear error' standard.
The appellate court should review the jury’s factual findings de novo.
The correct answer is appropriate because appellate courts review a jury’s factual findings under the 'clear error' or 'manifest error' standard, which highly defers to the jury’s determinations. This is due to the recognition that the jury had the opportunity to assess the credibility of witnesses and weigh evidence firsthand during the trial. Incorrect options fail to account for the deference owed to the jury, misstate the standard of review, or incorrectly apply legal standards meant for other issues. For example, appellate courts do not review de novo when it comes to questions of fact, as this undermines the jury's function.
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