What is the standard of review for an appellate court evaluating factual findings in a bench trial?

In a bench trial, where there is no jury and the judge serves as the trier of fact, the standard of review for an appellate court evaluating factual findings is "clearly erroneous." This means that the appellate court will generally defer to the trial court's findings of fact unless they are left with a definite and firm conviction that a mistake has been made. The rationale behind this standard is that the trial judge has the advantage of hearing witnesses and observing their demeanor, which provides a better context for assessing credibility and the nuances of the evidence presented.

The clearly erroneous standard acknowledges the trial court's unique position in determining the facts of the case. If the appellate court finds that the factual findings made by the trial judge are based on a reasonable interpretation of the evidence, it will not overturn those findings simply because it may have made a different decision had it been the trier of fact.

In contrast, the other standards of review listed serve different purposes: "de novo" is used primarily for questions of law, allowing the appellate court to review legal issues without deference to the lower court; "abuse of discretion" applies to cases where the trial court has decision-making authority, such as evidentiary rulings; and "substantial evidence" is