Scope of Review in Appeal

The Rules of Civil Procedure that govern federal civil cases also applies to the review of findings of fact in admiralty cases.  In admiralty cases, the finding of facts related to circumstances relating to the existence of an interest would be reviewed before awarding prejudgment interest.  The question as to whether the awarding of a prejudgment interest contained abuse of discretion is also reviewed.  If the district court tried the case without a jury, its legal conclusions and findings of facts will be reviewed by the appellate court for clear error.

When a Court of Appeals review an admiralty decree, it does not have to consider any error appearing on a record transmitted from a lower court for review, if the error is harmless.  The district court will be held to abuse its discretion only when its findings are erroneous or if it applies an incorrect legal standard in deciding the case.  The appellate court may not reverse the judgment of a trial court even after thoroughly checking all the evidence and feels that it would have weighed the evidence differently, provided that the court’s account of the evidence is reasonable in light of the record.  In deciding a question pertaining to jurisdiction, the appellate court may not disturb a lower court’s finding to have admiralty jurisdiction if the decision is free from doubt and the case is within the court’s federal diversity jurisdiction.


Inside Scope of Review in Appeal